# docs_fts_content

c1: EFTA00021161
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021161.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)
1"
Subject: RE: Forfeiture question
Date: Sun, 13 Oct 2019 21:10:12 +0000
Definitely feel free to kick him to us in the first instance if that's preferable, and yeah, the two of us and
His firm
generally represents a handful of people (most prominently
but others as well) but
we've primarily been dealing with Florida-based partner Sigrid McCawley and hadn't yet heard from Matt. Thanks.
From:
Sent: Sunday, October 13, 2019 17:07
To:
Cc:
is
1
Subject: Re: Forfeiture question
Who does he represent again? I'm inclined to tell him to talk to the case team in the first instance, unless you
guys would prefer us to be involved up front.
And remind me,
is on the team and should be included in emails? Anyone else at this point?
Sent from my iPhone
On Oct 13, 2019, at 5:05 PM,
)
wrote:
No, we haven't heard anything from them about forfeiture.
Sent from my iPhone
On Oct 13, 2019, at 5:02 PM,
wrote:
Do you guys know what this is about?
Sent from my iPhone
Begin forwarded message:
From: "Matthew L. Schwartz"
Date: October 13, 2019 at 2:58:27 PM EDT
To:
Subject: Forfeiture question
Do either of you guys or the appropriate other person have 2 minutes to discuss a somewhat time-sensitive,
but by no means urgent, Epstein-related forfeiture question in the next few days?
Matthew L. Schwartz
EFTA00021161

=== Page 2 ===
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
EFTA00021162


c1: EFTA00023229
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023229.pdf
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=== Page 1 ===
Event: Accepted: Brass Meeting on Epstein
Start Date: 2019-12-10 18:00:00 +0000
End Date: 2019-12-10 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-12-07 00:05:15 +0000
Date Modified: 2019-12-07 00:05:15 +0000
Priority: 5
DTSTAMP: 2019-12-06 23:10:19 +0000
Attendee:
EFTA00023229


c1: EFTA00021424
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021424.pdf
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=== Page 1 ===
From:
"
)"
To: "
Cc: "
'Martin
,
Weinberg'
N
""rweingarten@steptoe.com"
,
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Mon, 15 Jul 2019 22:16:50 +0000
Importance: Normal
Attachments: 2019-07-15,_JE,_speedy_trial_time_exclusion_request.pdf
To the Chambers of Judge Berman:
Attached please find a courtesy copy of the Government's request for the exclusion of speedy trial time in the above-
captioned case between July 15, 2019, and July 18, 2019. Defense counsel consents to this request and is copied here.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00021424


c1: EFTA00021383
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021383.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
To:
Subject: RE: My edits to sections V and VI
Date: Sat, 27 Feb 2021 01:15:49 +0000
Attachments: Section_V,_A_(P117).docx
Hey - this is the new paragraph from
that we discussed earlier. It's currently void of any highlighting. I pulled it
out for you to take a quick look at.
From:
Sent: Friday, February 26, 2021 8:07 PM
To:
Subject: My edits to sections V and VI
These are the last from me, thanks!
EFTA00021383


c1: EFTA00022150
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022150.pdf
c6: pdf
c7: images
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=== Page 1 ===
Event: Accepted: Brass Meeting on Epstein
Start Date: 2019-12-10 18:00:00 +0000
End Date: 2019-12-10 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-12-07 00:30:58 +0000
Date Modified: 2019-12-07 00:30:58 +0000
Priority: 5
DTSTAMP: 2019-12-07 00:12:48 +0000
Attendee:
EFTA00022150


c1: EFTA00022181
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022181.pdf
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=== Page 1 ===
From:
To:
Subject: FW: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 18:02:01 +0000
Good luck!!! Proud of you guys!!!
From:
Sent: Monday, November 29, 2021 12:59 PM
To:
Cc: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doi.gov>: USANYS-INVESTIGATORS<USANYS-INVESTIGATORS@usa.doi.eov>:
Subject: Re: United States V. Ghislaine Maxwell
opens
We (finally!) have our jury. Preliminary instructions are happening now, an
will open after lunch, around 1:45. Come
support!
Sent from my iPhone
On Nov 28, 2021, at 9:59 AM
wrote:
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00022181


c1: EFTA00022626
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c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022626.pdf
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=== Page 1 ===
From: "Singer, Linda"
To:
"
(USANYS)"
Subject: Call w/ DOJ re. Epstein SDNY Investigation
Date: Fri, 02 Oct 2020 16:15:46 +0000
Importance: Normal
Attachments: unnamed
Confidential & Privileged
Unless otherwise indicated or obvious from its nature, the information contained in this communication is attorney-client privileged and confidential information/work
product. This communication is intended for the use of the individual or entity named above. If the reader of this communication is not the intended recipient, you are
hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error or are not
sure whether it is privileged, please immediately notify us by return e-mail and destroy any copies-electronic, paper or otherwise-which you may have of this
communication.
EFTA00022626


c1: EFTA00022992
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c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022992.pdf
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=== Page 1 ===
From:
"
To:
Subject: Accepted: Call on Epstein
Date: Tue, 04 Feb 2020 15:32:32 +0000
Importance: Normal
Attachments: unnamed
EFTA00022992


c1: EFTA00023407
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023407.pdf
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=== Page 1 ===
From:
Subject: Accepted: Epstein-Related FOIA Requests
Date: Fri, 21 Feb 2020 16:42:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00023407


c1: EFTA00021352
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021352.pdf
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=== Page 1 ===
From:
To:
Subject: RE: Epstein victim call
Date: Thu, 25 Feb 2021 17:47:06 +0000
Thanks very much,
We will forward to the FBI.
From:
Sent: Thursday, February 25, 2021 12:46 PM
To:
is
is
(
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
,
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch with
either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had not
been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised that
someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we couldn't
find online). I believe the last communication we had with him was the attached.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021352


c1: EFTA00022654
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022654.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Report Number
Case Report
OCVAN Unit
2002-10
345 S County Rd.
Palm Beach Police
Palm Beach, FL
Date Opened
Date Closed
Review Date
Primary Case
Case Title
Employee
12/06/1901
//
11
Primary
Prostitution-Epstein
(Det.)
Assisting
Active?
Case Disposition
Source
Agency
Active
UNFOUNDED
Location (Arename / Case Location)
Zone
Beat
Grid
File Number
Date Entered
Entered By
Date Last Updated
Last Updated By
300-13
08/06/2004
Import
08/06/2004
Import
Narrative/Notes
12/07/01
File 100
Sgt.
On 12/06/01, OCVAN received intelligence from the WPBPD concerning Maxwell.
According to the report, Maxwell is hiring young women from PBAC to come toher
house and answer the phone. They are paid $200.00 per day for htis service. It
is unclear what is occurring in the residence, however, contact information for
PBAC students was provided. Follow-up will be initiated as soon as possible.
10/13/03
File 300-13
Det.
On 12/10/01, information was passed on from Sgt.
regarding Ghislaine Maxwell
and Jeffrey Epstein of 358 El Brillo Way. A West Palm Beach intelligence report
read as follows: "Three female college students from PBAC
(
)
were approached by an English woman who
identified herself as Maxwell, on the Palm Beach Atlantic Campus. Maxwell said
she needed young, beautiful unmarried women to answer phones and do office work at
her home on Palm Beach.
went to the house on several occassions and
described the telephone calls as men call in saying when they were going to drop
of particular girls. All three girls said Maxwell and Epstein were secretive
about what was going on at the house, and at least two of the girls complained
about Epstein touching them inappropriately. They said Maxwell asked for a list
of other girls who she could call to work on short notice. She said she needed a
large pool of girls to call as she did not know how many she would need at any
given time. The callers were receptive to the idea of forwarding numbers of
undercover personnel to Maxwell. Maxwell pays $200.00 per day for answering
phones (cash).
said she only worked there one day, but she hd been there
on at least one other occasion. I did not speak with
Their telephone
number is
at their dorm room on campus (roommates). Maxwell and Epstein
allegedly have a private plane and frequently go to New York leaving them out of
the area for extended periods of time."
Numerous attempts were made to reach the girls at the above listed number with
negative results. Finally, I contacted PBA security who stated the college was
closed for the semester and would not re open until next year.
In the beginning of January, many messages were left which met with negative
results.
Page I of 4
10/18/2005
Drug Trak Intelligence Management System - Institute of Police Technology and Management Jacksonville, Flerida
EFTA00022654

=== Page 2 ===
Narrative/Notes
A check of Jeffrey E Epstein, DOB
revealed an expired florida drivers
license of
Epstein did not return with any criminal history.
An Accurint check revealed he has a florida concealed weapon permit #9012027,
which expires on 03/29/05. Several ownership address were listed for Epstein
including 358 El Brillo Way, Palm Beach, 457 Madision Ave, New York, NY, and
numerous vehicle and watercraft ownerships. In addition, many UCC filings were
recorded. Finally, associations were listed with the following companies:
Ghislaine Corp (Inactive); Har Adom, Limited (CO-Active); L.A.W. Plantation
Management (GA-Active); Nine East 71st street Corp. (NY-Active); RHC Licensing
Corp (TX-Dead); and the other two Florida inactive corporations.
A check of Ghislaine Noelle Maxwell, DOB
, revealed a valid florida driver
license
), with no criminal history. An Accurint check on
Maxwell revealed numerous vehicles, with nothing additional.
On 1/28/02, trash pulls were initiated on this case, and conducted intermittently
through 4/16/02. Numerous intelligence items were discovered within the trash, to
include: individual directory listings for massages in New York, and the United
Kingdom, numerous phone messages, daily calendars, list of female names titled
"People that I want you to meet", listing females, ages, descriptions, and what
they do (trash pull on 3/29/02), front page of bell south phone bill indicating
phone account
under the name of Jeffrey Epstein and account
under the name of Ghislainne Maxwell, correspondence to
indicate a weapon is kept on the property, financial information, nude photographs
of women and numerous references to massages through daily calendars, phone
messages, etc. It should be noted a list was complied of all names associated
with Epstein/Maxwell/358 El Brillo Way, and is documented in the file.
It should be noted that all attempts to reach reporting parties have met with
negative results at this time.
On 02/8/02, an investigative subpoena was completed requesting all incoming and
outgoing lines to the address 358 El Brillo Way.
On 02/13/02, the above referenced subpoena was received from the SAO and was
served on Bell South via fax.
On 02/12/02, an inquiry into corporations on line revealed Jeffrey E. Epstein
related to three Florida entities: Financial Strategy Group, Inc; Ghislaine Corp;
Financial Trustees, Inc. None of the aforementioned entities are active.
On 02/22/02, I received information from Bell South which revealed the following
telephone lines are installed at 358 El Brillo Way:
Under name G. Maxwell
Jeffrey Epstein Main house line
All above lines are considered to be residential lines.
On 02/27/02, an investigative subpoena was completed requesting all incoming and
outgoing calls rom 1/28/02 through 2/4/02 on the following telephone numbers:
2002-10 Prostitution Epstein
Page 2 of 4
10/18/2005
Drug Trak Intelligence Management System Institute of Police Technology and Management - Jacksonville, Florida
EFTA00022655

=== Page 3 ===
Narrative/Notes
On 02/28/02, 411 computer checks revealed the lines
and
to be
listed under the name Jeffrey Epstein.
On 03/1/02, the above referenced subpoena was received from the SAO and was
served via fax to Bell South.
On 03/5/02, a fax was received from Bell South indicating the subpoena has been
received and Bell South was working on the information.
On 03/11/02, documents phone records were received from Bell South and evaluated.
With the exception of their being numerous phone lines at the residence, nothing
unusual was detected.
On 03/19/02, an investigative subpoena was completed requesting all incoming and
outgoing calls rom 1/28/02 through 2/4/02 on the following telephone numbers:
On 03/20/02, the above referenced subpoena was received from the SAO and was
served via fax to Bell South on 03/21/02.
On 03/26/02, drive by surveillance revealed the following vehicle tags:
Jeffrey Epstein,
Jeffrey Epstein, and
On 03/29/02, additional phone records from Bell South were received and evaluated.
It should be noted nothing usual was detected within these records.
I subsequently contacted security at PBAC and advised them of the information
received from WPBPD. They provided the following information:
and
are now living off campus at
long term physical address is
long term physical address is
Security stated these two
are roomates at
and their phone number is
In
addition,
is residing on campus at a different location than last
semester. Security agreed to conduct an unannounced room search on
advised will me as soon as that is complete. I advised them I will not attempt and
contact until the search has been done.
On 04/12/02, I was contacted by PBA Security. A room search was conducted and
the following report provided: "At 1420, 020411 a room search was conducted in
by Sgt.
Officer
and the Director of Security
per the request of Residential Life (
accompanied the officer's to
was not present during the search. Six full bottles and two empty bottles
of Smirnoff Ice were found in
standing closet. Along with the illegal
alcohol, several papers were found by
personal laptop computer that had
what appeared to be porn site addresses on them. These papers were not
confiscated due to there being other personal related information on them.
A check of the one address: www.enjoy.com proved to be an adult internet sit with
visual pornography on it.
Another piece of paper that was seen indicated that information had been obtained
about some type of adult work that paid $2,200.00 weekly.
Nothing else found.
is handling all discipline."
2002-10 Prostitution-Epstein
Page 3 of 4
10/18/2005
Drug Trak Intelligence Management System Institute of Police Technology and Management - lacksonville, Florida
EFTA00022656

=== Page 4 ===
Narrative/Notes
Security explained to me that
will no longer be allowed to reside at the
PBAC campus, however,
will contact me with whatever address
moves to.
Later, I was contacted with the following address for
:
A cell phone number of
was provided for
On 04/24/02, Sgt.
and I interviewed
and
.
Both subjects
confirmed they had been approached by Maxwell and had worked at the residence
briefly answering phones, and were paid well. Although they felt there was
something "weird" about the subjects residing there,
and
advised they
did not observe anything illegal at the time.
On 04/25/02, Sgt.
and I met with
stated that
did
not recall anything illegal occurring at the residence, there were nude
photographs of women all over the residence.
added there were women running
around the pool area topless, and that people were always getting massages.
stated that Epstein offered a massage to
at one time, (he did not physically
do the massage-a tech did it), but Epstein had
take her top off for the
massage.
stated that made
extremely uncomfortable and
has not been
back since.
Although it appears as though usual activity is occurring at this residence, at
this time, no illegal activity has been reported or detected. This information
will remain as intelligence purposes only, until a crime is reported or possibly
another student or young female and report to us while working at the residence.
Links
Expenses/Income
- 0
Source Payments
- 0
Aircraft
- 0
Associated Cases
- 0
Arrests
- 0
Arrest Charges
- 0
Arrest Warrants
- 0
Businesses
- 0
Case Logs
- 0
Confiscations and Seizures
- 0
Associated Employees
- 0
Evidence
- 0
Gangs and Groups
- 0
Locations
- 0
Media
- 0
People
- 0
Search Warrants
- 0
Vehicles
- 0
Watercraft
- 0
2002-10 Prostitution-Epstein
Page 4 of 4
10/18/2005
Drug Trak Intelligence Management System Institute of Police Technology and Management - Jacksonville, Florida
EFTA00022657

=== Page 5 ===
Persons System Report
ADULT
OCVAN Unit
4
345 S. County Rd
3
Palm Beach Police
Palm Beach, FL
Report Date
Name
Address
10/18/2005
Epstein, Jeffrey E
358 El Brillo Way Palm Beach, FL 33480
DOB
X
If
Weight
Hair
Eyes
Ethnic
3
52
M
W
72
0
CAUCASIAN
Driver License
SSN
FBI Number
(FL)
B
Agency Number
Other Number
Employer
File Number
Category
300-13/2600-
Scars/Marks/Tattoos
No Photo Available
Drugs
Crimes
Review Date
Source
11
INTEL REPO
Area Name
Zone
Beat
Grid
Addresses
358 EL BRILLO WAY PALM BEACH, FL 33480
Import From Persons
Associates
Unknown
W/F
Girlfriend
Maxwell, Ghislaine
W/F
12/25/1961
Media
EPSTEIN_175
IMAGE
EPSTEIN_175.JPG
Notes
See Drug Trak Case #2002-10
See associate Ghislaine Maxwell
03-11-04
File # 2600
Det.
On 03-05-04,
completed an intel regarding a WF
,
last name
unknown, who was giving a message to Jeffery Epstein at 358 El Brillo.
stated that several times Epstien asked her to take off her top or her pants. She
refused.
contacted the police department later that day and wanted to make
a complaint. She also said that she would work with police. I contacted
on 03-06-04 at 11:00 p.m. and introduced myself then told her that I wouild contact
her at a later date.
On 03-11-04, I left a message for
to call me regarding the Epstien
incident. Her phone number is
.
Investigation Continues
File 2600
August 10, 2004
Det.
EFTA00022658

=== Page 6 ===
Notes
On August 10, 2004 I received an intelligence report written by Off.
indicating that he had been flagged down by a taxi cab driver who had just dropped
off two unknown white females, who appeared to be approximately 15 and 17 yoa, at
the residence of Epstein, 358 E1 Brillo Way. The taxi cab drive stated that he
picked the females up in West Palm Beach and while traveling to Epstein's residence
he overheard the females discussing how much money they would make "dating" in Palm
Beach and possible drug use.
Off.
drove by the residence and observed two vehicles in the driveway, one
registered to Epstein, a black Chevy
and a black Mercedes bearing
which came back as no record found.
Det.
would also complete a drive by later in the evening and observe a white
female enter a small red vehicle,
This vehicle is registered to
DOB
No further information regarding known criminal activity obtained; however, efforts
will be made to commence trash pulls from Epstein's residence in the near future.
Attached is the Intel report provided by Off.
File 300
November 29, 2004
Det.
On November 29, 2004 I reviewed an intelligence report completed by Officer
regarding
According the report,
who is the property manager for 358 El
Brillo Way, which is the residence of Jeffrey Epstein, responded to the Police
station to report that a suspicious vehicle was parked in the driveway of the
residence.
Upon arrival, Off.
came into contact with
who advised that she was there
to pick up an envelope from the homeowner (Epstein).
stated that Epstein
did leave an envelope for
and went inside to retrieve it. While waiting,
received a phone call and stated, "I can't talk, I can't talk, I'm at school, I
gotta go" before terminating the call. When questioned who had called
advised
it was her mother.
was advise that she works at
and was introduced to Epstein through a friend who worked there.
told
that Epstein allows then to come over anytime and use the house and pool.
would ask
what was in the envelope that was given to
and was
told it was money for being a message therapist.
confided, orr the
record, he (Epstein) has many young girls come over for that there's always a
different young girl at the pool or inside with him when he's here.
Detectives will attempt contact with
in the near future for possible follow-up
assistance.
Nothing further at this time.
CC: Jeffrey Epstein
File 2600
January 18, 2005
Det.
Persons System Report for Epstein, Jeffrey E
EFTA00022659

=== Page 7 ===
Notes
On or about January of 2005, I located an article on the internet regarding Jeffrey
Epstein. The article details some of the financial ventures and background
regarding Epstein. According the this article, Epstein is a financial manager and
only has a clientele with a net worth of 1 billion dollars.
Attached is article for informational purposes.
File#2600
Det:
03/31/2005
On March 30, 2005, I was asked to begin conducting surveillance and trash pulls
reference Detective investigating Epstein as a suspect involved in a sexual
battery of a 14 year old female. I was advised that Epstein was possibly engaging in
sexual contact with young females.
March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor,
and requested trash pulls for 358E1 Brillo Way to begin on March 31, 2005.
March 31, 2005 at 9:20 a.m., I met with Town of Palm Beach sanitation employee,
Jeffrey who collected seventeen white plastic trash bags from Epstein's property and
turned them over to me.
I took the trash bags to the sanitation office were I sifted through them. I
collected mail correspondence from Armani Exchange addressed to
"Jeffrey E. Epstein" notepaper with
,
a important message
notepaper addressed to J.E dated 03/29/05 at 8:15 p.m. reference
U.S
Airways boarding pass copy for passenger,
Montgomery County,
Maryland Health Department food service ID NO#40820 for
and
Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash
collected were attached with the supplement.
March 31, 2005, at 3:00 p.m., I set up a surveillance vehicle equipped with a video
monitoring device. The surveillance vehicle was parked approximately fifty feet east
of Epstein's driveway, to monitor and record all vehicle and pedestrian traffic
entering and leaving Epstein's property.
Video surveillance was conducted near Epstein's property from March 31 through April
3, 2005.
The video surveillance tapes were regularly changed out with new tape. Six Maxell T
-160 VHS tapes were reviewed for intelligence. The tapes were filed in the OCVAN
office.
End of supplement.
File#2600
Det:
04/01/2005
On April 01, 2005 at 9:30 a.m., while parked in the area of 358 El Brillo Way
waiting to collect Epstein's trash from public works, I observed a white female, who
I recognized as
from her Florida driver's license search I conducted
from mail correspondence collected from the trash. I made no contact with
While parked in the area, I also observed Epstein's GMC Yukon truck
leave the property . as well as other vehicles arrive and park across the street from
the property. The occupants of these vehicle appeared to be house workers,
maintenance, and gardeners.
At 9:38 a.m., I collected trash from sanitation employee,
I sifted through
the trash and collected mail correspondence addressed to Jeffrey Epstein, automotive
records and personal documents for
and
as well as
Persons System Report for: Epstein, Jeffrey E
EFTA00022660

=== Page 8 ===
Notes
"Jeffrey Epstein" notepaper with girls names and times
1).
I also found a three inch purple finger size object which had a broken end. The
object appeared to be a broke piece from a sexual toy (Cyclone Vibrator) possibly
used for rectal gratification. The object was photographed for Detective
packaged in a bio-hazard evidence bag (possible body fluids) and secured as
investigative evidence.
Copies of the trash collected were attached with the supplement.
End of supplement.
File#2600
Det:
04/05/2005
On April 05, 2005 at 9:18 a.m., I collected trash from sanitation employee,
I transported the trash bags back to the sanitation site, where I sifted through the
trash bags and collected mail correspondence addressed to Jeffrey Epstein as well as
notepaper (Important Message) names and telephone numbers. The following are items
of paper collected from Epstein's trash.
)
blank piece of white paper
)
black paper
black paper
)
)
MSN Hotmail web page with email address
)
The following items were documented for Detective
investigation prior to
disposal.
End of supplement.
File: 2600
Det:
04/21/2005
During the month of April 2005, trash pull were conducted at 358 El Brillo Way to
gather further intelligence related to Detective
investigation of Jeffrey
Epstein possibly being sexually involved with underage girls.
Trash from Epstein's residence was collected by Palm Beach Sanitation employee,
, The trash bags from Epstein's were turned directly over to me upon
driving away from the property on most days, however if I was unable to met with
, he would leave the Epstein's trash bags at a designated area at the
sanitation office.
All trash collected from Epstein's which included, mail correspondences addressed to
Jeffrey Epstein, and other household members, notepad papers, with names, telephone
numbers, notes and a three inch purple object that appeared to be part of a sexual
toy were turned over to Detective
-
The six Maxell T-160 vhs video tapes collected from the surveillance remained in my
custody.
End of supplement.
File#2600
Det:
06/14/2005
Persons System Report for : Epstein, Jeffrey E
EFTA00022661

=== Page 9 ===
Notes
On June 14, 2005, Detective
contacted me and advised that the
airplane belonging to Jeffrey Epstein of 358 E1 Brillo Way was parked at Palm Beach
International Airport.
Detective
requested that I begin trash pulls for the purpose of gather
intelligence.
I made contact with
of Palm Beach Sanitation and requested that on
June 15, 2005, all of Epstein's trash be collected and transported to the sanitation
department.
End of supplement.
File 100
September 12, 2005
Det.
On or about September 11, 2005,
was arrested for possession of
marijuana in the north end of the island during a traffic stop by Off.
See
case number 05-1263 for further information.
Previous intelligence indicates that
may have been paid money for sexual acts
from Jeffrey Epstein.
would have been under the age of 18 at the time this act
would have allegedly taken place.
On September 12, 2005 I made telephone contact with
at phone number
stated that she was willing to speak with me about a resident on the
island involved in "disgusting activity".
indicated that this person was of
high influence and had 6 to seven assistants working for him.
stated that she
has heard he also has police officers working for him.
discussed her concerns
about the marijuana arrest and stated that she is know living in outside of
Jacksonville and would not be able to assist police.
indicated that she would
come to the police department today; however, it was determined by
that she should be more thoroughly interviewed at a later date.
It should be noted that Epstein's name was not mentioned during the entire
conversation and
was instructed not discuss this matter with anyone else.
indicated that she last spoke with Epstein through e-mail approximately 2 weeks ago.
was further asked to save/document any future correspondence.
Det. Bureau (
)
notified of
information.
Sgt.
05-368
2600
September 21, 2005
On Wednesday September 21, 2005 Detective
requested that the trash at
be collected for evidentiary purposes. I contacted Sanitation Supervisor
at ext
and requested that the trash be collected while an
investigator observes the collection. He then contacted
, who is the
employee on that route and informed him to contact me prior to picking up the trash.
At 9:30 a.m., I had not received a call from Mr.
so I responded to the area
to wait for him to arrive. As I approached
I observed
driving his collection vehicle eastbound on
to
d. I met
with
on South County Road and collected four bags from the back of his
truck. I then responded to the Police Department and informed Detective
that
I would search through the trash. He then met with me in the basement area and
assisted in the search for items. Several items of paper with information either
typed or handwritten was taken into evidence.
Persons System Report for: Epstein, Jeffrey E
EFTA00022662

=== Page 10 ===
Notes
Contact was made with Supervisor
,
to request that trash be collected again
on Friday September 23, 2005.
Investigation Continuing.
File 2600
September 23, 2005
Det.
On or about September 23, 2005 at approximately 0915 hours, I responded to 358 E1
Brillo and met with PB Sanitation worker
I observed
enter
the driveway of 358 El Brillo and remove several plastic bags of trash and place the
contents into the back of an empty sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There were a total of 4 white in color plastic bags
and each contained documentation and correspondence for 358 El Brillo and Jeffrey
Epstein. All documents of evidentiary value were removed and turned over to Det.
for follow-up.
No further action taken.
File 2600
September 23, 2005
Det.
On or about September 26, 2005 at approximately 0900 hours, I responded to 358 E1
Brillo and met with PB Sanitation worker
I observed
enter the
driveway of 358 E1 Brillo, where no trash was located within the receptacles. I
left the area without incident and notified Det.
to that affect.
On or about September 27, 2005 at approximately 0915 hours, I responded to 358 E1
Brillo and met with PB Sanitation worker
I observed
enter the
driveway of 358 El Brillo and remove one plastic bag of trash and place it in the
back of an empty sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There were a total of 1 white in color plastic bag
which contained correspondence for 358 El Brillo. All documents of evidentiary
value were removed and turned over to Det.
for follow-up.
No further action taken.
On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358
El Brillo and met with PB Sanitation worker
I observed
enter the driveway of 358 El Brillo and remove several plastic bags of trash and
place the contents into the back of an empty sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There were a total of 7 white in color plastic bags
with a red tie and 1 black in color bag which contained 2 white in color plastic
bags with a red tie. Each of the bags contained documentation and correspondence
for 358 El Brillo and Jeffrey Epstein. Also located was a broken piece of a hard
Persons System Report for : Epstein, Jeffrey E
EFTA00022663

=== Page 11 ===
Notes
plastic or clear acrylic stick, which was shaped with small ridges. This device is
commonly used as a sexual toy which is inserted into the vagina or anus for
stimulation. This item, along with all documents of evidentiary value were removed
and turned over to Det.
for follow-up.
On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358
El Brillo and met with PB Sanitation worker Jeff
I observed
enter the driveway of 358 El Brillo and remove several plastic bags of trash and
place the contents into the side well of the sanitation truck. This side of the
truck is separate from the rear of the truck and does not come into contact with
other trash.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There were a total of 2 white in color plastic bags
which were tied at the top. Each of the bags contained documentation and
value were removed and turned over to Det.
correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary
for follow-up.
File 2600
October 5, 2005
Det.
PBPD 05-368
On or about Wednesday October 5, 2005 at approximately 0928 hours, I responded to
358 El Brillo and met with PB Sanitation worker Jeff
I observed
enter the driveway of 358 E1 Brillo and remove several plastic bags of trash and
place the contents into the bed of the sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents, with the assistance of Det.
There were a
total of 2 bags, one of which was white in color and tied in a knot at the top, and
the other was a black in color bag, which contained two white in color trash bags
along with loose debris. Each of the bags contained documentation and
value were removed and turned over to Det.
correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary
for follow-up.
File 2600
October 5, 2005
Det.
PBPD 05-368
On Friday, October 7, 2005 at approximately 0923 hours, I responded to 358 E1 Brillo
and met with PB Sanitation worker
I observed
enter the
driveway of 358 El Brillo and remove several plastic bags of trash and place the
contents into the bed of an empty sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There were a total of 3 bags, one of which was white
in color and tied in a knot at the top, and the other two bags were black in color.
One bag contained documentation and correspondence for Jeffrey Epstein, which was
copied and given to Det.
for informational purpose. It is described as a
white piece of stationary with "Jeffrey E. Epstein" typed at the bottom. Handwritten
on the letter was, "Luba Sunday 100 (1:00), Improve Saturday 1500 Bay Road Miami
Flamingos Beach". Nothing of evidentiary value was located.
Persons System Report for Epstein, Jeffrey E
EFTA00022664

=== Page 12 ===
Notes
File 2600
October 5, 2005
Det.
PBPD 05-368
On Monday, October 10, 2005 at approximately 0943 hours, I responded to
and met with PB Sanitation worker
I observed
the driveway of 358 El Brillo and remove a plastic bag . of trash and place it enter into
the bed of an empty sanitation truck.
I then followed
to a predetermined location and seized the trash from the
truck. The trash was transported to the Palm Beach Police Department where I began
sifting through its contents. There was one white in color plastic bag which was
tied in a knot at the top. The bag contained nothing of evidentiary value.
NOTE:
FILED
AS OF 10/11/2005 ALL NEW SUPPLEMENTS FOR JEFFREY EPSTEIN SHOULD BE
# 2600-8
Links
Activities
- 0
Addresses
- 1
Aircraft
- 0
Aliases
- 0
Arrests and Charges
- 0
Arrest Warrants
- 0
Associates
- 2
Businesses
- 0
Cases
- 0
Gangs and Groups
- 0
Locations
- 0
Media
- 1
Telephone Numbers
- 0
Vehicles
- 0
Watercraft
- 0
Persons System Report for : Epstein, Jeffrey E
EFTA00022665


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c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Subpoena Contact
Date: Wed, 31 Jul 2019 21:56:29 +0000
Attachments: Epstein_Subpoena_Index.xlsx
Hi
Attached is an index listing the subpoenas we have sent out and an indication of whether we have received a response. I
only marked an entry as non-responsive if we received nothing from the entity. For instance, if we received a letter stating
a lack of records, that was still marked as yes. So for any entry labeled "No", we received nothing. If you have any records
we are missing please send them over, and if we have any outstanding subpoenas the AUSAs are hoping you can check in
with the entities.
Let me know if you have any questions, or if I can be of any help.
Thanks,
Andy
From:
Sent: Thursday, July 25, 2019 6:51 AM
To:
Subject: RE: Subpoena Contact
1030 works. My desk number is
-
On Jul 24, 2019 4:42 PM,
) [Contractor]"
wrote:
Hi
Does 10:30 work for you?
Thanks,
Andy
From
Sent: Wednesday, July 24, 2019 4:34 PM
To:
Subject: RE: Subpoena Contact
I will be in the office around 9 tomorrow morning. Let me know what time is good for you.
-
EFTA00021741

=== Page 2 ===
On Jul 24, 2019 1:15 PM,
wrote:
Hi
Thanks again for helping with this project. By way of introduction, I've copied Andy Hamilton, a paralegal in our
unit. If you could please connect with Andy to discuss this project, that would be great. I've spoken with him about
what we're hoping to accomplish, so he can bring you up to speed, but if either of you have questions, please let us
know.
Thanks--
Assistant United States Attorney
Southern District of New York
One Saint
Plaza
New York, NY 10007
Original Message
From:
Sent: Wednesday, July 24, 2019 1:01 PM
To:
Cc:
Subject: Subpoena Contact
Hey
,
I just wanted to let you know that our Intel Analyst Natalie Beck will be the point of contact for the subpoena info to
coordinate with your paralegal. She is cc'd on this email.
Special Agent
FBI New York
VCAC/Human Trafficking
C:
EFTA00021742


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 11061344 has received final approval
Date: Fri, 21 Feb 2020 18:47:32 +0000
Importance: Normal
Dear
Travel authorization 11061344 has received final approval.
Trip ID: 11061344
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13402 - Epstein Investigation - Witness interview
Destination: Los Angeles, CA, United States
Dates: 2020-02-26 - 2020-02-29
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0006
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00020836


c1: EFTA00020495
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c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
Document
signed
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/24/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/24/2020 04:31 PM EDT
Details:
On 08/24/2020, at 4:31 p.m. Eastern Time,
,
date of birth
telephone number
/
home address
,
Lodi, CA 95242, called the FBI National Threat Operations Center (NTOC)
to report he was raped by Jeffrey Epstein.
provided the following information:
On 12/05/1993,
helped a man on Wilshire Blvd, in Beverly Hills, CA
who had a flat tire. The man introduced himself as Jeffrey Epstein.
Epstein offered to take
to his ranch in New Mexico that day and
agreed.
was taken to a private airport and flown to an air strip a
couple of miles from Epstein's ranch.
was taken downstairs to the "strippers lounge." On his third Pepsi,
become unconscious.
woke to being
He saw three young boys also strapped down next to him.
believed the boys were about 17 years old.
and the boys had their
stated
that he drifted in and out of consciousness during the incident.
UNCLASSIFIED
EFTA00020495

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/24/2020
While he was awake,
was able to see a deformed penis. As Epstein held
him down with his right hand, Epstein left hand reach across him.
saw
a red spot one-quarter of the way down Epstein's left arm.
woke up
on the couch to two armed guards inside the room. He indicated that his
clothing was wet, like he was put in the shower. He requested to return
to California. The armed guards came with them on the return trip and
did not tell anyone about the incident.
is attempting to hire a lawyer to file a civil suit against Epstein's
estate.
did not remember the attorney's name; however, the
attorney's telephone number is
and in the Los Angeles area.
UNCLASSIFIED
2
EFTA00020496


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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Witness torpedoes Prince Andrew's denials about alleged Epstein sex slave | Toronto Sun
Date: Sat, 08 Feb 2020 15:01:44 +0000
https://torontosun.com/news/world/witness-torpedoes-prince-andrews-denials-about-alleged-epstein-sex-slave
Sent from my iPhone
EFTA00021113


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: MCC Employee Summary Table
Date: Tue, 13 Aug 2019 18:10:57 +0000
Attachments: MCC_Officer_Information.xlsx
For your review for chiefs/brass.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00022628


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c0:
=== Page 1 ===
From:
"
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Subject: Prince Andrew
Date: Tue, 25 Feb 2020 15:55:13 +0000
Embedded: FW:_DOJ_ongoing_Investigation.imsg; Fwd:_U.S._Department_of_Justice_investigation.msg
There are two chains that I believe capture everything. The first (Fwd: U.S. Department of Justice Investigation) I believe
captures everything from initial outreach to the last email, which is the second attachment (FW: DOJ ongoing
Investigation).
EFTA00023409


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=== Page 1 ===
From: "Martin G. Weinberg"
To:
)"
Cc:
)"
)"
, Reid Weingarten
Subject: RE: US V Epstein
Date: Fri, 26 Jul 2019 18:37:36 +0000
Thanks
Could I burden you, your team to break out of the intended first discovery production and to email to Reid and
myself as soon as you are able the search warrants and affidavits and if they are easily available the returns,
thanks, Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the
contents of this message is prohibited.
Original Message
From:
) [mailto:
Sent: Friday, July 26, 2019 1:48 PM
To:
Cc:
)
Subject: RE: US V Epstein
Marty,
Thank you. Regarding discovery, we expect to make an initial production no later than Tuesday, and we expect it
will be electronic discovery in native format -- that is, PDFs, JPEGs, etc. (in other words, not .tiff and load files
as is sometimes the case).
thanks,
Original Message
From: Martin Weinberg
Sent: Friday, July 26, 2019 13:43
To:
Cc: Martin Weinberg
Subject: US V Epstein
EFTA00021662

=== Page 2 ===
I am in receipt of your earlier email about preservation/production and will have a responsive letter to you no
later than Monday morning (hopefully today or over weekend).
- can you advise us as to when we will receive the initial discovery subject to the now issued
Protective Order and to the extent it is an electronic production, its format so that we can have Steptoe IT prepare
for its receipt.
Thanks
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the
contents of this message is prohibited.
EFTA00021663


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: metadata
Date: Tue, 27 Apr 2021 23:46:53 +0000
Attachments: USGME01088996.doc
Can you tell what device this came from? Thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00020785


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: BRO-ExecAssistant-S BRO-ExecAssistant-S
>, Christian Everdell
"Mark
S. Cohen"
Subject: Re: URGENT RE: Ghislaine Maxwell 02879-509
Date: Mon, 28 Dec 2020 16:09:14 +0000
Thank you for the information.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Dec 28, 2020, at 11:00 AM,
wrote:
Good afternoon:
Ms. Maxwell has three blankets and had those blankets throughout the
weekend. Although one was removed, it was in fact replaced shortly
thereafter. Additionally, Ms. Maxwell was provided a holiday meal and
all additional meals she is entitled to. The temperature was checked on
the night of 12/26/20 and was reported to be 76.5 degrees.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
EFTA00022316

=== Page 2 ===
Metropolitan Detention Center Brooklyn
80 29th Street
Brooklyn, New York 11232
P:
E:
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all
accompanying documents constitutes sensitive information. This
information is the property of the U.S. Department of Justice. If you
are not the intended recipient of this information, any disclosures,
copying, distribution, or the taking of any action in reliance on this
information is strictly prohibited. If you received this message in
error, please notify us immediately to make arrangements for its return
to us.
BOBBI C STERNHEIM
12/26/2020 4:37 PM
Good afternoon-
I am informed that Ms. Maxwell's blanket has been removed and that she
was not
provided a complete holiday meal.
She is cold and hungry.
I am urging you to immediately provide her with blankets.
She is cold, her isolation cell is not insulated, and the temperature
drops in the evening.
It is currently a freezing 32 degrees and the temperature is forecast
to drop to at least 28 degrees this evening.
It is inexcusable for her to be deprived of a blanket and proper
nutrition.
Despite repeated complaints, the MDC fails to provide basic
requirements to Ms. Maxwell.
I am requesting an emergency legal call with her. My number is
Promptly correct these problems, which will be reported to the Court.
Thank you-
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
EFTA00022317

=== Page 3 ===
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.
EFTA00022318


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c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: Re: JE iPhone review
Date: Sat, 07 Nov 2020 04:52:18 +0000
Hi,
Happy to- I am away this weekend but I have my personal laptop and can remote in sometime tomorrow.
Provided I'm able to download it, I should be able to review, and I'll let you know if that doesn't work for some
reason.
Sent from my iPhone
On Nov 6, 2020, at 11:19 PM,
)
wrote:
He
I've divided up the remainder of Epstein's iPhone into three chunks.
is taking the videos. There's one chunk
(containing four chats, audio files, documents, voicemails, and recordings) that I'm hoping you would be able to review
tomorrow. I've saved that chunk here on the share: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\FOR AM
Any chance you could please review this chunk tomorrow please? In the meantime, and I'm working through all of the
images.
Thanks so much,
EFTA00020831


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=== Page 1 ===
£50
Bank
England
FIFTY
bounds
£20
BANK ENGLAND
£20
EZN
100
£20
I'JU
BANK ENGLAND
I'JU
100
FRANCS
£20
BANK ENGLAND
£20
I'v
100
VARIOUS
BANK ENGLAND
£20
£20
BCE
100
DOLLARS
I'JU
i'ju
100
£20
BANK ENGLAND
£20
£20
BANK ENGLAND
£20
BCE
I'JU
100
£20
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=== Page 1 ===
From:
)"
To: Susan Necheles
Cc: "Kathleen E. Cassidy"
)"
(USANYS)"
,
Bcc:
Subject: Re: Draft Statement
Date: Fri, 11 Dec 2020 00:24:53 +0000
Embedded: Re:_Draft_Statement_msg
Sender:
Subject: Re: Draft Statement
Message-Id: <22EEADE5-D1F2-4D42-9B6F-EBFFBA6C2E22@usa.doj.gov>
To:
Cc:
Cc:
EFTA00023220


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=== Page 1 ===
From:
)"
To:
Cc:
"
)"
i
(USANYS)"
Bcc: "USAHUB-USAJournal111
Subject: FW: EMail 1 of 2: EPSTEIN - A
signed application/affidavit
Date: Thu, 29 Oct 2020 17:45:55 +0000
Embedded: FW: EMail 1 of 2: EPSTEIN -
Sender:
Subject: FW: EMail 1 of 2: EPSTEIN - AUSA Comey Det Byrne, signed application/affidavit
Message-Id:
<SN5P110MB05425D0602FF1087AAF0BD6F92140@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
Cc:
Cc:
EFTA00021114


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
USDC SDNY
New York, New York 10007
DOCUMENT
ELECTRONICALLY FILED
DOC #:
November 10, 2021
DATE FILED: 11/11/21
BY EMAIL
The parties are ORDERED to submit the lists
The Honorable Alison J. Nathan
referenced in this letter on or before November 14,
United States District Court
2021, in accordance with Dkt. No. 427. The parties
Southern District of New York
may continue submitting proposed redactions in
United States Courthouse
accordance with the procedures this Court has
40 Foley Square
previously set. so ORDERED.
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Alin I. Netto
11/11/21
Dear Judge Nathan:
At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint
letter regarding protections for witness identities at trial. In particular, the Court directed the
parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose
procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury
regarding witnesses testifying under pseudonyms or under their first name only, and (4) address
the logistics of offering sealed or redacted exhibits containing personal identifying information.
Below are the positions of the parties regarding these logistical considerations. Because this letter
contains identifying information relating to victims, the Government respectfully requests that the
Court accept the Government's proposed redactions to this letter.
Government position:
I.
Nomenclature
With respect to nomenclature for witnesses whose identities should be protected at trial,
the Government respectfully submits the following chart, which provides the true names of
witnesses and the proposed nomenclature for those witnesses at trial.
EFTA00023378

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 2 of 5
Page 2
The Government submits that this nomenclature can be used when trial begins on
November 29, 2021, but that the parties should be directed to continue referencing victims and
witnesses on the public record according to the nomenclature in the Superseding Indictment. The
Government further requests that the defense be directed to redact the true names of the witnesses
in this chart from all exhibits to filings, and to avoid using the true names of victims in filings with
the Court. Using the true names of victims delays public filings and creates otherwise unnecessary
redaction projects that waste the Government and the Court's time. Moreover, using victim names
in filings increases the risk that victim identities may become public, due to redaction errors or
other issues.
II.
Voir Dire
Regarding voir dire, the Government proposes that prospective jurors be handed a sheet
with a list of names and places that may come up at trial. That sheet, which would be filed under
seal, would contain the true names of witnesses. The sheet would not be read aloud; instead, the
EFTA00023379

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 3 of 5
Page 3
Government requests that the Court direct prospective jurors to read the sheet and to raise a hand
if they are familiar with the witnesses or locations. Examination of jurors on this subject would
then be conducted at sidebar, with the transcript redacted to remove witness identifying
information.
III.
Limiting Instruction
The Government requests that the Court give the jury an instruction that is similar to the
instruction Judge Garaufis gave the jury in United States V. Raniere, 18 Cr. 204 (E.D.N.Y.). In
that case, Judge Garaufis instructed the jury:
You may have noticed during yesterday's testimony that the witness used first
names of certain individuals. That is because the names of certain alleged victims
are being withheld from the public and the press to protect the privacy of those
individuals. I have therefore instructed the parties to refer to those individuals by
their first names only; however, those full names are known to the Government, the
defendant, and to the Court.
An excerpt of the relevant transcript is enclosed as Exhibit A. Here, the Government proposes that
the Court instruct the jury:
At this trial, certain witnesses will be testifying under their first name only. Other
witnesses will be testifying under pseudonyms - that is, under different names.
That is because the names of certain alleged victims and related witnesses are being
withheld from the public and the press to protect the privacy of those individuals. I
have therefore instructed the parties to refer to those individuals by their first names
only, or in some instances, by using a pseudonym. However, the full names of the
witnesses are known to the Government, the defendant, and to the Court.
The Government respectfully submits that the proposed instruction addresses any potential
EFTA00023380

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 4 of 5
Page 4
prejudice to the defendant, as the instruction makes clear to the jury that the identities of the
witnesses are being protected from the public and press only, and that the true names of the
witnesses are known to the Government, the Court, and the defendant.
IV.
Sealed and Redacted Exhibits
The Government anticipates offering certain exhibits entirely under seal or with redactions
to protect the personal identifying information of witnesses and third parties. With respect to
logistics, the Government would propose submitting redacted versions of exhibits - along with an
index noting which of the Government exhibits will be offered under seal - no later than November
29, 2021. To the extent the defense takes issue with the sealing requests or the proposed redactions,
the Court may rule on those exhibits on case-by-case basis during the trial.
The Government has considered how best to publish sealed exhibits to the jury while
protecting the identities of witnesses and the privacy of third parties. On that score, the
Government is mindful that exhibits published in electronic format on screens in the courtroom
may be seen by the public, since the screens at counsel table - and potentially the jury box- are
visible to the public from certain angles. For this reason, the Government requests permission to
provide jurors with individual binders containing sealed exhibits. The Government expects that
jurors will follow the Court's instruction to only view items in the binder when the Court instructs
jurors to do so.
EFTA00023381

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 5 of 5
Page 5
Defense position:
In light of the Court's ruling on the government's motion in limine, the defense will accept
the government's proposed nomenclature for the witnesses referenced above. The defense has no
objection to the procedures proposed by the government for voir dire and for sealing and redacting
exhibits on the understanding that the defense will have the opportunity to object to particular
sealing and redaction requests. The defense also proposes the following limiting instruction in
place of the government's proposed instruction:
This case has received, and will continue to receive, significant attention in the
media. To minimize the inconvenience and potential harassment of any witness, the
Court has permitted witnesses, if they choose, to be referred to by either their first
name or a pseudonym. However, the full names of the witnesses are known to the
Government, the defendant, and to the Court, and were shown to you during jury
selection. This process should not bear in any way on your evaluation of the
evidence in this case.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By email)
EFTA00023382

=== Page 6 ===
Prage6106f72
Proceedings
245
1
the aspects of the motion we filed, and I think it's a lot for
2
the Court to have to deal with, quite frankly, and I know the
3
Court is going to try and do the best it can with the
4
situation, but I don't think it's tenable and -- I don't ask
5
for mistrials easily, I have probably asked for four in my
6
entire career, I don't see a way out of this problem.
7
(Pause.)
8
THE COURT: All right, I'm going to deny the
9
defendant's motion for a mistrial. Any issues caused by a
10
witness referring to certain individuals by their first name
11
only and by asking the Government if they may use last names
12
of certain other individuals can be cured by a jury
13
instruction, which I will give. Going forward, the Government
14
shall provide the defendant and each witness, including the
15
current witness, with a list of the individuals whose identity
16
should be protected from the public and the press, that way
17
each witness can refer to the list rather than asking the
18
Government whether a particular individual's identity is
19
protected.
20
You don't have a proposed jury instruction.
21
MS. PENZA: Not yet, Your Honor.
22
THE COURT: I have one.
23
To the jurors: You may have noticed during
24
yesterday's testimony that the witness used first names of
25
certain individuals. That is because the names of certain
Denise Parisi , RPR , CRR
Official Court Reporter
EFTA00023383

=== Page 7 ===
Prage7206f72
Proceedings
246
1
alleged victims are being withheld from the public and the
2
press to protect the privacy of those individuals. I have
3
therefore instructed the parties to refer to those individuals
4
by their first names only; however, those full names are known
5
to the Government, the defendant, and to the Court.
6
You may also have noticed that the witness was
7
asking the Government whether she should say the last names of
8
certain individuals. Going forward, the witnesses will
9
receive a list of the individuals whose last names are to be
10
protected to which they may refer while testifying.
11
Anything else you want me to put in there?
12
MS. PENZA: Not from the Government Your Honor.
13
THE COURT: You object?
14
MR. AGNIFILO: I do, Judge.
15
THE COURT: Your objection is noted.
16
Also, I'm going to direct that the parties shall not
17
make any speaking objections. If the basis for an objection
18
is not apparent, the parties may request a sidebar.
19
MR. AGNIFILO: Very good. Thank you, Judge.
20
THE COURT: Okay, what else?
21
MS. PENZA: Nothing else from the Government, but we
22
would just ask for five minutes to make sure that the list is
23
correct for the current witness.
24
THE COURT: All right, we'll take a five-minute
25
break.
Denise Parisi , RPR , CRR
Official Court Reporter
EFTA00023384


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=== Page 1 ===
From: "
To: "Zaveri, Mihir"
Cc:
Subject: Re: NYT inquiry: Jeffrey Epstein injured in jail?
Date: Thu, 25 Jul 2019 06:00:50 +0000
Mihir, we can't confirm and have no comment.
On Jul 24, 2019, at 11:03 PM, Zaveri, Mihir
wrote:
Hello, this is Mihir Zaveri, reporter at The New York Times.
We are seeing reports that Jeffrey Epstein was found injured in his jail cell after a possible suicide attempt or
some sort of assault.https://www.nbcnewyork.com/news/local/Jeffrey-Epstein-Found-Injured-in-NYC-Jail-
Cell-After-Possible-Suicide-Attempt-or-Assault-Sources-513174311.html
Hoping tonight to confirm this or get any insight into what might have actually happened and where he is right
now.
I can be reached at
Mihir
EFTA00022538


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=== Page 1 ===
Event: Accepted:
proffer (re abuse)
Start Date: 2019-12-04 20:00:00 +0000
End Date: 2019-12-04 23:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-12-04 17:51:35 +0000
Date Modified: 2019-12-04 17:51:35 +0000
Priority: 5
DTSTAMP: 2019-12-04 17:26:23 +0000
Attendee:
)
EFTA00020969


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=== Page 1 ===
From:
To:
Cc:
Subject: SDNY Press Clippings, August 4, 2020
Date: Tue, 04 Aug 2020 17:57:39 +0000
GHISLAINE MAXWELL
WaPo: Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general and the
medical examiner say it was suicide
TMZ: President Trump Suggests Jeffrey Epstein Might've Been Killed in Jail
Business Insider: Trump again wishes Jeffrey Epstein's alleged madam Ghislaine Maxwell 'well' as she awaits
trial on sex trafficking charges
Newsweek: Why No Ghislaine Maxwell Pictures Have Been Released Since Her Arrest
COHEN
NYT: https://www.nytimes.com/2020/08/04/us/politics/trump-prosecutors.html
Insurance Journal: Manhattan District Attorney Says Trump Probe Includes Alleged Insurance, Bank Fraud
TRUSTED TRAVELER
NYT: The Arc of Homeland Security Bends Toward Trump. Chad Wolf Bends With lt.
MATTERS OF INTEREST
NYT: Disputed Ballots Must Be Counted in N.Y. Congressional Race, U.S. Judge Rules
WSJ: Kodak Loan Disclosure and Stock Surge Under SEC Investigation
NYT: Mexico Purges Security Agencies of Those Tied to Ex-Chief
NYT: https://www.nytimes.com/2020/08/04/nyregion/nyc-shootings-coronavirus.html
PROPUBLICA: Justice Department Is Scrutinizing Takeover of Credit Karma by Intuit, Maker of TurboTax
LAW.COM: Novartis Agrees to Pay $678M for Illegal Kickbacks in 'Sham' Speaker Scheme
EFTA00021168


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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:08:49 +0000
Inline-Images: image001.png
Congratulations!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO ENTED VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
EFTA00021823

=== Page 2 ===
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
EFTA00021824

=== Page 3 ===
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00021825


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: United States V. Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 27 Jul 2020 22:26:28 +0000
Attachments: GM,_protective_order,_clean_version.docx
Attached is a Word version of the proposed protective order we submitted to the Court. In regards to your prior email, it
sounds like it would be a more productive discussion after you have had the chance to review the redline of our proposed
order. So we propose a call at 9:30am tomorrow morning. Let us know if that works for you and I will circulate a dial-in.
Thanks,
From:
Sent: Monday, July 27, 2020 5:43 PM
To:
Cc:
Subject: RE: United States V. Maxwell, 20 Cr. 330 (AJN)
We also request that the defense provide the Government with a Word version of its proposed protective order
submitted to the Court earlier today. We are not able to run a redline using the filed version.
Regards,
From:
Sent: Monday, July 27, 2020 16:43
To:
Cc:
Subject: RE: United States V. Maxwell, 20 Cr. 330 (AJN)
Pursuant to the Court's Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m.
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant's
current position on the following:
-
Whether you are aware of any case in any federal district in which a protective order was entered in a criminal
case that prevented the Government from showing its own documents to prospective witnesses or their counsel
without requiring restrictions upon those witnesses and their counsel;
EFTA00020670

=== Page 2 ===
-
Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to
reference by name - rather than by pseudonym or other anonymized identifier - any victim in a public statement
or publicly-docketed filing (and rather than by sealed filing, if such named identification is necessary), such that
the Government may consider whether it can formulate language to address any such concerns, without
conceding any right of the defendant to name any individual who has self-identified as a victim of Jeffrey Epstein
or Ghislaine Maxwell at any time; and
-
Whether the defense is willing to itself propose any language to address the Government's concerns in relation
to the issue described immediately above, regarding the defendant's desire to be able to reference by name any
victim in a public statement or publicly-docketed filing, without conceding that any such right exists.
Additionally, also relating to the production of discovery, please mail, or otherwise have delivered, a 1 terabyte hard drive
for purposes of the Government's discovery production. While we are in the process of determining the size of an initial
production, and the size may total substantially less than 1 terabyte, that will ensure our ability to make a robust initial
production and should be suitable for subsequent productions as well. That can be sent to my attention at our Office.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00020671


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c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash
EVCP Sub ]
Date: Mon, 22 Nov 2021 19:04:34 +0000
Attachments: 2021.11.22_JSP_Letter_Response_to_Motions_to_Quash.pdf
Inline-Images: image001.jpg
Defense response on the motions to quash
From: Nicole Simmons
Sent: Monday, November 22, 2021 1:41 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca
>; Laura Menninger
is
i
>;
(USANYS)
is
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP Sub ]
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Letter Motions to Quash her Rule
17(c) subpoena to the Epstein Victims' Compensation Program.
Pursuant to our established protocol, we are submitting the Response to the Court under temporary seal to allow the
government to propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
80203
PH
FX
DIRECT:
www.hmflaw.com
EFTA00021030


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=== Page 1 ===
From: The Bloomberg Open <1
To:
Subject: [EXTERNAL] The 0 word
Date: Mon, 29 Nov 2021 12:09:15 +0000
Bloomberg
EFTA00022125

=== Page 2 ===
EFTA00022126

=== Page 3 ===
Opinion
EFTA00022127

=== Page 4 ===
On trial. Ghislaine Maxwell-the 59-year-old British socialite who has
pleaded not guilty to trafficking underage girls for sex with former boyfriend
Jeffrey Epstein-is getting closer to her moment of reckoning. Final jury
selection and opening arguments in her trial start today. Maxwell faces up
to 40 years if convicted on the most serious charges. As for her time in jail,
you guessed it: she hates it.
FOLLOW US
GET THE NEWSLETTER
EFTA00022128

=== Page 5 ===


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=== Page 1 ===
From:
Subject: FW: Re: Suicide reconstruction report
Date: Tue, 08 Sep 2020 15:59:47 +0000
FYI
From:
Sent: Tuesday, September 8, 2020 11:54 AM
To:
Subject: RE: Re: Suicide reconstruction report
There is no specific time frame at the moment. I forwarded the request up my leadership chain on Friday. It is being
processed through the various relevant parties. Once I have new information I will notify you.
Thanks,
^^^
>
9/8/2020 10:54 AM >>>
Thank you for your reply. Can you please provide a time frame regarding further response/access to report. I just need to
let AUSAs know that its in the works. Thank you,
From:
Sent: Tuesday, September 8, 2020 10:41 AM
To:
Subject: FW: Re: Suicide reconstruction report
Thanks for reaching out about this report. I have consulted with my leadership and we will reply. Please let me know if you
have any questions.
Thanks,
EFTA00023013

=== Page 2 ===
(C)
>>>
>
9/4/2020 1:15 PM >>>
I am attempting to get a copy of Jeffrey Epstein's final suicide reconstruction report for requesting AUSAs. Can you please
assist me with this request. Thank you,
From:
Sent: Friday, September 4, 2020 1:10 PM
To:
Subject: RE: Re: Suicide reconstruction report
was the team leader for the suicide reconstruction. His number is
e-mail
?
>
9/4/2020 1:06 PM>>>
Can you please direct me to the appropriate POC at the Central Office regarding report? I am trying to run this down for
the AUSAs - Thank you!
From:
Sent: Friday, September 4, 2020 12:25 PM
To:
Subject: Fwd: Re: Suicide reconstruction report
I do not have a copy. I am sure is somewhere in Central Office, but has not been issued out.
>>>
9/3/2020 9:06 AM>>>
Sirs,
Do you guys have an official/final suicide reconstruction report from the Epstein suicide? OIG has made a couple of
requests and I wanted to provide them the report so they can appropriately reply to the AUSAs. I have never seen the
EFTA00023014

=== Page 3 ===
report and wasn't sure who maintained it because
does not have it either.
Since I am no longer at NYM, if you feel more comfortable replying to OIG directly (attached), I understand. I just want to
ensure we are responsive to the request so as not to cause any issue with the ongoing legal proceedings.
Thanks for your help.
EFTA00023015


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=== Page 1 ===
From:
To:
(USANYS)"
Cc:
)"
)"
Subject: Re: motions under seal?
Date: Fri, 02 Aug 2019 16:25:25 +0000
Ok, thanks for letting us know your position. We will email you the motion a bit later today and write the court
Monday.
Garden City, NY 11530
On Aug 2, 2019, at 12:10 PM,
(USANYS)
wrote:
,
We had the court seal the documents, and per the Court's request, are following up with a formal letter request to do
so. We do not believe there is a legitimate legal basis to seal
statements, but if you can point us to any
authority, we are happy to look at it.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 12:07 PM
To:
(USANYS)
is
Cc:
is
i
in
Subject: RE: motions under seal?
We will take care of that error and apologize for it.
I know that the statements are not marked as sensitive by the Government but for obvious reasons we don't want to
file those publically. Thus our request. If the government won't consent then, we will serve you via email and hold off
filing it until we can get the court to rule.
Garden City, NY 11530
EFTA00021746

=== Page 2 ===
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From:
(USANYS) [mailto:
Sent: Friday, August 02, 2019 11:50 AM
To:
)
Cc:
(
);
(
);
Subject: RE: motions under seal?
As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive
discovery that cannot be publicly filed.
statements to law enforcement do not fall into the sensitive
category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery
and references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed
four documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective
order. We will be asking the Court to remove them from the docket and you will need to refile.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:33 AM
To:
(USANYS)
is
Cc:
is
(
)
>;
is
Subject: RE: motions under seal?
I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today
or easily. Nor do I want the extra work.
Garden City, NY 11530
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From:
,
(USANYS) [mailto:
Sent: Friday, August 02, 2019 11:26 AM
To:
)
Cc:
(
);
(
);
Subject: RE: motions under seal?
EFTA00021747

=== Page 3 ===
It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you
file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the
unredacted version and discuss what, if anything, can be unredacted for the public version.
Assistant United States Attorney
From:
Sent: Friday, August 2, 2019 11:03 AM
To:
)
y
(USANYS)
Cc:
is
)
>;
is
Subject: motions under seal?
Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data,
which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we
discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the
Government position about filing that motion under seal?
Also,
affidavit hasn't been signed because the only regular access to a notary are members of his legal team and
we don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open
court at our next appearance.
Garden City, NY 11530
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00021748


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10810811(1) has received final approval
Date: Sun, 24 Nov 2019 23:06:55 +0000
Importance: Normal
Dear
Final voucher 10810811(1) has received final approval.
Trip ID: 10810811
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13176 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Santa Monica (City), CA, United States
Dates: 2019-11-14 - 2019-11-15
Current status: Voucher Awaiting Payment
Voucher total expenses: 740.28
Estimated trip cost: 1067.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
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.
EFTA00020915


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=== Page 1 ===
From: Sigrid McCawley
To:
Cc:
Subject: RE: Interviews - 10/22 and 10/23
Date: Tue, 15 Oct 2019 14:33:41 +0000
Hello
- sorry for the delay but I have been trying to get a handle on who is coming for the meeting etc.
is a victim that I think will be helpful to your continuing investigation. She is working hard with your
victims' coordinator to see if she can get here for the meeting. If she gets her passport/visa clearance and gets to the US
then we could do an interview on the afternoon of Tuesday October 22rd starting at 2:00 if that works. I think she will
probably take a bit longer because she was brought to the US by Epstein a number of times so maybe a lot 2 hours for the
interview (from 2-4).
is going to be attending the meeting and she said she could interview with you right after the
meeting. I believe the notice says the meeting starts at 10:00 on October 23rd so maybe we plan to meet you at 12:00
depending on the length of the victims' meeting.
also wanted to come to the meeting. I know you met with her for a short while. If you would like to meet
with her for a more detailed interview we could do that on the afternoon of October 22nd from 4 - 6 if that works.
is
She would like to try to attend via skype or some kind of conference line.
I know you interviewed her sister
If you would like to also interview
I can set something up.
Let me know if that works.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
) [mailto:
Sent: Thursday, October 10, 2019 3:39 PM
To: Sigrid McCawley
Cc:
is
is
Subject: Interviews - 10/22 and 10/23
Hi Sigrid,
EFTA00021327

=== Page 2 ===
Hope you're doing well.
mentioned that some of your clients might be interested in being interviewed while they
are in New York on 10/22 and 10/23. We'd be happy to get times on the calendar. Would you please let us know who
would be available for interviews and what dates and times work for each client?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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
EFTA00021328


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=== Page 1 ===
From: Daniel Cundy
To:
)"
Cc:
)"
)"
>, Gary Bloxsome
"Jennifer
,
Richardson"
Subject: Reference materials further to our call
Date: Sun, 09 Aug 2020 16:29:52 +0000
Attachments: Ormerod-Release-13-lleaf_A7_(002).pdf DEPP_7.2_(003).pdf
Inline-Images: image854761.jpg; image532909.jpg; image421070.jpg; image733915.jpg
Dear
Apologies for the slight delay.
Please find attached an extract from The Decision Procedure and Penalties manual (DEPP 7) from the Financial Conduct
Authority handbook - drawing attention to 7.2.14. This practice and approach resonates with the law as set out in United
States V. Allen, 864 F.3d (2d Cir.2017). We also attach an extract from the publication 'Montgomery and Ormerod on
Fraud: Criminal Law and Procedure' (2008) which summarises the approach taken by the Serious Fraud Office (see A7-
327) to the limitations and protections on use when their compulsory powers are used in MLAT requests, an approach
which reflects such cases as Kastigar V. United States, 406 U.S. 441 (1972) as well as decisions in UK domestic law. We
reiterate the protection at Article 7 (2) of the MLAT treaty although there is no need to attach it.
Kind regards
Daniel Cundy I Partner
RANKED IN
Chambers
Blackfords LLP
I
London
EC4M 7EF
UK
500
UNITED
www.blackfords.com
2020
TOP TIER
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
Daniel Cundy I Partner
RANKED IN
Chambers
Blackfords LLP
I
London EC4M 7EF
UK
500
KINGDOM
|
www.blackfords.com
2020
TOP TIER
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
EFTA00022199

=== Page 2 ===
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00022200


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=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To:
)"
)"
(USANYS)"
Cc: "Mark S. Cohen" <mcohen@CohenGresser.com>, Bobbi Sternheim
<bcsternheim@mac.com>, Jeff Pagliuca <jpagliuca@hmflaw.com>, "Laura Menninger"
<lmenninger@hmflaw.com>
Subject: RE: Discovery Requests
Date: Mon, 01 Feb 2021 03:41:26 +0000
Inline-Images: image001.jpg; image002.jpg
Hi
We will provide you with a drive to load the files. If our messenger service is functioning tomorrow (depending on the
severity of the snow storm) we will drop it off tomorrow. If not, we will drop it off Tuesday morning.
Thanks,
Chris
From:
Sent: Friday, January 29, 2021 4:41 PM
To: Christian Everdell;
(USANYS)
Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger
Subject: RE: Discovery Requests
Chris,
Our paralegals reminded me that we have produced the ranges you included in your most recent email twice: once in the
third production (08-21-2020) and once in the reproduction with shortened file names (09-03-2020). We can certainly
produce them a third time, but we would not be able to reproduce them again through your FTP link, as they are too
large. Please provide us with a 64 GB drive if you would like us to reproduce those ranges.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
From
Sent: Friday, January 29, 2021 4:08 PM
To: Christian Everdell
) ;
(USANYS)
Cc: Mark S. Cohen ; Bobbi Sternheim ; Jeff Pagliuca ; 'Laura Menninger'
Subject: RE: Discovery Requests
Chris,
Thank you for sending the link. I will ask our paralegals to use it to send you the ranges you requested, including the
ranges you referenced in your most recent email.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00020978

=== Page 2 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Friday, January 29, 2021 3:53 PM
To:
)
(USANYS)
Cc: Mark S. Cohen <mcohen@CohenGresser.com>; Bobbi Sternheim <bcsternheim@mac.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>; 'Laura Menninger' <Imenninger@hmflaw.com>
Subject: RE: Discovery Requests
Thanks for the follow-up. Please send the documents to the FTP link below:
https://cohengresser.sharefile.com/r-r16397a3bc183400da73b80cbfa69f256
Also, we are missing the Bates ranges listed below.
SDNY_GM_00167911 through SDNY_GM_00168477
SDNY_GM_00168488 through SDNY_GM_00169165
SDNY_GM_00169184 through SDNY_GM_00169491
SDNY_GM_00169505 through SDNY_GM_00169735
We had discussed these ranges several months ago and I believe you had agreed to reproduce them in the 11/9
production. But we do not appear to have received them. Can you send these ranges via the FTP site as well?
Thanks,
Chris
From:
Sent: Friday, January 29.2021.10:31 AM
To: Christian Everdell;
)
(USANYS)
Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger
Subject: RE: Discovery Requests
Chris,
Following up on this, we have now prepared all of the items you requested in point 6 below for production to you. Our
paralegals have sent a copy of the materials to the MDC for your client. Would you like to provide us with an FTP link for
this production, or would you like us to prepare a CD for you instead?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, January 25, 2021 3:56 PM
To: 'Christian Everdell' <CEverdell@CohenGresser.com>;
(USANYS)
Cc: 'Mark S. Cohen' <mcohen@CohenGresser.com>; 'Bobbi Sternheim' <bcsternheim@mac.com>; 'Jeff Pagliuca'
<jpagliuca@hmflaw.com>; 'Laura Menninger' <Imenninger@hmflaw.com>
Subject: RE: Discovery Requests
Chris,
Following up on point 6 below, our paralegals have re-stamped the materials you identified with a Bates range overlap
and are prepared to reproduce those materials to you. The materials are small enough to produce via your FTP site.
Would you like to send us a link to where you would like those materials uploaded? Alternatively, we can load the
materials to a CD and send it to you.
We are still waiting to hear back from our vendor about the remaining issues you identified in point 6.
Thanks,
EFTA00020979

=== Page 3 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Sunday, January 17, 2021 10:05 PM
To: Christian Everdell <CEverdell@CohenGresser.com>
(USANYS)
Cc: Mark S. Cohen <mcohen@CohenGresser.com>; Bobbi Sternheim <bcsternheim@mac.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>; 'Laura Menninger' <Imenninger@hmflaw.com>
Subject: RE: Discovery Requests
Chris,
Below please find our responses.
1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery
produced to date. It took a significant amount of time to create this copy due to the volume of discovery and
delays on the part of our vendor, who assisted in creating the copy.
2. As we have recently discussed, Ms. Maxwell now has a drive containing the contents of the CD produced on
November 18, 2020.
3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all
contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was
extracted. In our November 18, 2020 discovery letter, we provided you with a chart setting forth which "NYC"
CART Evidence Number corresponds with which Subject Device in our warrants. If you still need a detailed index
of all 1.2 million documents with the specific Subject Device indicated, please let me know, and I will ask one of
our paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was recovered
from one of Epstein's devices. In other words, we did not apply any redactions to that document; rather, the
redactions existed on the document at the time the document was found during the FBI's search of Epstein's
devices. We are not aware of any legal basis for your request for a log of redactions. If you have any legal
authority on that point, we would be happy to consider it. As a courtesy, I will note that our office did not apply
redactions to any material that was identified responsive during the searches of Epstein's devices.
5. We are aware of our discovery obligations, have complied with them, and will continue to comply with them. We
are not aware of any legal basis for your request that we inform you of what, if any, documents have been
withheld or the basis for their withholding. If you have any legal authority on that point, we would be happy to
consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all
records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August
5, 2020 production included two documents. The first (SDNY_GM_00005532-5649) is the document you
referenced in your email inquiry. The second (SDNY_GM_00005650-5676) is 27 pages long, accounting for the
first 27 pages of the production from Rodgers. We produced those two documents in the form in which we
received them.
6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach back
out to you once I have an update on the status of those issues.
7. We do not have a more detailed index of the November 9 and November 18 productions beyond what we have
provided to you.
8. We are not aware of any legal basis for your request for copies of grand jury subpoenas. Nor are we aware of any
legal basis for your request that we identify the date range of documents we requested in each subpoena. If you
have any legal authority for those requests, we would be happy to consider it.
9. The court filings that appear to be referenced in the Daily Beast article you sent are an application for a search
warrant and a search warrant filed in the District of New Hampshire. We produced both documents to you in
discovery on August 5, 2020. The DNH judge issued a sealing order in connection with the warrant and
application. As you can see at Bates No. SDNY_GM_00000621, the sealing order automatically expired on
EFTA00020980

=== Page 4 ===
December 30, 2020. Our understanding is that the District of New Hampshire unsealed the filing of its own accord
in conformity with the clear language of that sealing order. Our office took no affirmative steps to unseal or
otherwise release these filings.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGresser.com
Sent: Thursday, January 7, 2021 4:13 PM
To:
(USANYS)
Cc: Mark S. Cohen <mcohen@CohenGresser.com>; Bobbi Sternheim <bcsternheim@mac.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>; 'Laura Menninger' <Imenninger@hmflaw.com>
Subject: Discovery Requests
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at the
MDC so that she can read the files on the MDC computer. We will provide whatever media device you require to
facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the AT&T documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that
Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide an explanation
why you are not producing them to us. Please confirm whether there are other documents that were removed
from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
EFTA00020981

=== Page 5 ===
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
C. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on the
court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7268
ceverdell@cohengresser.com I view bio
www.cohengresser.com
New York I Paris I Washington DC I London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual
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EFTA00020982


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=== Page 1 ===
5
LB1TMAX1
1
precluding the term "victim" is both unnecessary and
2
impractical. United States V. Dupigny, 18 CR 528, transcript
3
of October 17, 2019, Docket No. 198 at 50. It is appropriate
4
for the government to use the terms as representative of its
5
litigating position. If the government does this in any way
6
that is atypical or unduly prejudicial, I will revisit.
7
Defense only cites out-of-circuit or state court
8
decisions for the proposition that those terms are inherently
9
prejudicial and harm the presumption of innocence. Numerous
10
courts of appeal disagree with that argument, particularly when
11
the presentation of evidence and the court's instructions
12
"taken as a whole clarify the government's burden of proving
13
all elements of the crime." United States V. Washburn, 444
14
F.3d, 1007, 1113 (8th Cir. 2006); see also, Server V. Mizell,
15
902 F.2d 611, 615, (7th Cir. 1990); United States V. Granbois,
16
119 F.App'x 35, 38-39 (9th Cir. 2004).
17
Defendant's lone district court opinion does not tip
18
the balance of this authority. I will, of course, instruct the
19
jury repeatedly that the defendant is presumed innocent and
20
that it is the government's burden and the government's burden
21
alone to prove guilt beyond a reasonable doubt. Those
22
instructions will eliminate any potential prejudice. See again
23
Judge Furman's decision in Dupigny, Docket No. 198 at 49
24
That matter resolved, I will turn to the government's
25
first motion. This goes to pseudonyms. The government moves
SOUTHERN DISTRICT REPORTERS, P.C.
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6
LB1TMAX1
1
pursuant to the Crime Victims Rights Act, 18 USC Section 3771,
2
to permit certain witnesses and certain non-testifying
3
witnesses to be referred to by pseudonyms. And there is also
4
the issue of redacting related exhibits that contain the names
5
or specifically identifying information. Specifically, the
6
government requests that eight individuals be referred to by
7
pseudonyms or their first name.
8
The defense is already aware of the identities of all
9
of these individuals, and as the government proposes it, the
10
jury will also be aware of the individuals' real identities.
11
The request only implicates how those individuals are referred
12
to in open court.
13
This is well-tread territory, and I will grant the
14
request for the following reasons:
15
The burden to justify this type of request, of course,
16
starts with the government. It "must provide a reason for the
17
limitation." United States V. Marcus, which is 2007 WL 330388
18
at *1, an Eastern District decision citing United States V.
19
Marti, 421 F.2d 1283 (2d Cir. 1970).
20
I agree with the government that limiting disclosure
21
here would protect the alleged victims from potential
22
harassment from the media and others, undue embarrassment and
23
other adverse consequences. The Court has an obligation under
24
the Crime Victims Rights Act to take certain measures at trial
25
to protect the dignity and privacy of alleged victims. 18 USC
SOUTHERN DISTRICT REPORTERS, P.C.
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7
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1
Section 3771 (a) (8).
2
It is quite common for alleged victims, both in cases
3
that have garnered media attention and those involving
4
allegations of sex abuse, to testify or be referred to by
5
pseudonyms or first names. Courts have allowed this whether or
6
not the alleged victims are minors or adults or adults
7
testifying about abuse that allegedly occurred when they were
8
minors.
9
Let me give a bit of a string cite here. See, for
10
example, United States V. Kelly, No. 19 CR 286, which is a high
11
publicity trial involving adults testifying about sex abuse as
12
minors, and that's in the Eastern District of New York; United
13
States V. Raniere, No. 18 CR 204, a high-publicity trial
14
involving at least one adult testifying about sex abuse as
15
minor; United States V. Dupigny, No. 18 CR 528, involving sex
16
trafficking, United States V. Kelly, No. 7 CR 374, and that
17
could be found at 2008 WL 5068820, which is an Eastern District
18
case involving an adult testifying about sex abuse as a minor;
19
United States V. Graham, No. 14 CR 500, found at 2015 WL
20
6161292 (S.D.N.Y., October 2015), that involved adults
21
testifying about sex trafficking as minors; United States V.
22
Gardner, No. 16 CR 20135, found at 2016 WL 5404207, an Eastern
23
District case from 2016 involving adults and adults testifying
24
about sex abuse as a minor, and collecting similar cases.
25
The practice has been widely permitted because
SOUTHERN DISTRICT REPORTERS, P.C.
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1
requiring alleged victims to publicly provide their names could
2
chill their willingness to testify for fear of having their
3
personal histories publicized. Raniere, Docket No. 622 at 32.
4
Given the sensitive and inflammatory nature of the
5
conduct alleged, such publicity may cause further harassment or
6
embarrassment, and other alleged victims of sex crimes may be
7
deterred from coming forward. See, Martinez, 17 CR 281,
8
(E.D.N.Y. 2017), Docket No. 34.
9
Limiting the disclosure of alleged victims' identities
10
in this case furthers these important interests. The same is
11
true with the identities of certain witnesses, although not
12
alleged victims themselves, because the disclosure of their
13
identities would necessarily reveal the identities of the
14
alleged victims.
15
I'm not persuaded by defense counsel's arguments to
16
the contrary. First, the defense notes that Ms. Maxwell does
17
not pose a threat to any of the witnesses. That is plainly
18
true, and the government does not argue or suggest or allege
19
otherwise, but just because that reason for limiting
20
disclosures is absent in this case does not eliminate the
21
possibility of other justifications. And again, there is a
22
need here to prevent undue embarrassment, harassment from the
23
press and third parties, and any resistance of others to come
24
forward and report alleged abuse. Cases establish that this is
25
sufficient
SOUTHERN DISTRICT REPORTERS, P.C.
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LB1TMAX1
1
Moreover, any potential prejudice in this regard can
2
be cured with an appropriate instruction explaining that the
3
reason for the precaution is regard for the witnesses' and
4
alleged victims' privacy, and that no inference can or should
5
be drawn against the defendant because of these precautions
6
My colleagues in this district and elsewhere have used
7
such an instruction in similar cases. The defense's concern
8
that this sort of instruction affords "Court-sanctioned
9
sympathy and credibility" is unfounded. My instructions on the
10
law will clearly and repeatedly instruct the jury on the
11
presumption of innocence and their sole role in assessing
12
witness credibility
13
Nor am I persuaded by the defense's arguments that the
14
fact that some alleged victims have previously publicly
15
disclosed some of their allegations obviates the need to limit
16
disclosure. As another district court has held, "just because
17
some victims' names are publicly available does not mean that
18
the details of their experience are already available." "
19
Raniere, Docket No. 662 at 34, n. 17
20
As I acknowledged in my protective order for this
21
case, "Not all accusations and public statements are equal.
22
Deciding to participate in or contribute to a criminal
23
investigation or prosecution is a far different matter than
24
simply making a public statement relating to Ms. Maxwell or
25
Jeffrey Epstein.' Docket No. 37 in this case at 2.
SOUTHERN DISTRICT REPORTERS, P.C.
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LB1TMAX1
1
The government anticipates that the alleged victims
2
will "testify in explicit detail and/or be the subject of
3
highly sensitive and personal testimony concerning illegal
4
sexual abuse. Thus, there's good reasons to limit public
5
disclosure of their names and specifically identifying
6
information during trial in this highly publicized case
7
involving highly sensitive issues."
8
Since there is a valid reason to limit disclosure in
9
this case, the defense must proffer a particularized need for
10
the disclosure of the relevant information, which is weighed
11
against the risks to the witnesses. I'll cite here, for
12
example, United States V. Marcus, again citing the Second
13
Circuit case in United States V. Marti.
14
As both parties acknowledge, the government's request
15
potentially implicates the defendant's right under the Sixth
16
Amendment's confrontation clause which guarantees defendants
17
the right to cross-examine adverse witnesses. The Second
18
Circuit has identified two central interests defendants have in
19
the public airing of identifying information about witnesses.
20
Again referencing the Marti case, 421 F.2d 1263.
21
The first is not relevant here because, as I have
22
noted, the defense is aware of the alleged victims' and
23
witnesses' identities.
24
The defendant argues that the second interest,
25
however, is implicated. Namely, defense may need the witness
SOUTHERN DISTRICT REPORTERS, P.C.
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11
LB1TMAX1
1
to reveal identifying information because knowledge of that
2
information by the jury might be important to its deliberations
3
as to the witness's credibility or knowledgability. That's
4
quoting the Marti case again. In particular, the defense
5
argues that revealing the alleged victims' and witnesses'
6
identities is necessary to probe the nature of the alleged
7
victims' occupations as relevant to the credibility and elicit
8
certain impeachment evidence.
9
I agree that such cross-examination cannot be unduly
10
limited and the government concedes the same. The government's
11
motions in limine 15, n. 6; government reply at 17 to 18. And
12
I will ensure that it is not.
13
My decision today grants the government's request to
14
limit the public disclosure of the alleged victims and some
15
witnesses' names and other specifically identifying
16
information, such as the specific names of current and past
17
employers, names of family members and addresses.
18
Limiting disclosure of the specifically identifying
19
information does not limit the anticipated cross-examination
20
that the defense described in its papers. All lines of inquiry
21
the defense outlined in its response are available without
22
disclosing specific names of employers or other specifically
23
identifying information. For example, the defense can probe
24
the genre, nature, and trajectories of witnesses' careers
25
without eliciting the specific employer name, but the defense's
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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=== Page 8 ===
12
LB1TMAX1
1
cross-examination should not include specifically identifying
2
information, and counsel must act responsibly doing SO. If,
3
after good faith effort in that regard is made and the defense
4
at some point feels they have hit a wall and can articulate a
5
specific need with respect to a particular line of questioning,
6
they can reraise the issue with opposing counsel and with me.
7
So that's my ruling on that motion. That said, I do
8
strongly encourage the government to speak candidly with the
9
anticipated witnesses so that they're clear eyed about what
10
this process will entail, the fact that cross-examination will
11
not be curtailed beyond the specific identifying information
12
that form the basis of the government's request, and the
13
possibility that despite these measures their identities may
14
become known and revealed to the public.
15
Should any of those witnesses or the government choose
16
not to proceed by pseudonym, the government shall let defense
17
counsel and the Court know. In the meantime, the government
18
and defense counsel shall confer about names that will be used
19
and any additional process for facilitating the clear
20
presentation of evidence. The Court will adopt a clear and
21
straightforward approach and the parties are admonished to come
22
to agreement on the use of pseudonyms and/or first names.
23
First assignment, there will be others, by November 10
24
the parties shall submit a joint letter to the Court under seal
25
explaining the nomenclature that they propose be employed with
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00023376

=== Page 9 ===
13
LB1TMAX1
1
respect to the actual identity of each witness.
2
As I mentioned, I do agree with the government that a
3
limiting instruction explaining the reasons for the precautions
4
is appropriate. In light of my ruling, I expect the parties to
5
confer and jointly propose such a limiting instruction.
6
Homework No. 2. This shall also be filed jointly by
7
November 10, and that can be filed on ECF.
8
There are some logistics of voir dire related to this.
9
Some of my colleagues have used the list method that the
10
government proposes on page 15, footnote 5 of their motion, and
11
I agree that this proposal makes sense. Once again, the
12
parties shall confer and submit on ECF by November 10 a joint
13
proposal for any logistical issues related to this for voir
14
dire.
15
That leaves the issue of sealing unredacted exhibits
16
and the limited redacting of exhibits containing specific
17
personal identifying information. The government shall manage
18
the logistics of this process throughout trial. So think
19
through and include in your November 10 submission on ECF the
20
specifics of this part of the process so that the trial
21
exhibits can be contemporaneously marked with the appropriate
22
limited redactions, and the government will need to manage this
23
on an ongoing basis throughout trial.
24
Government's motion 2, the alleged victims' prior
25
consistent statements. So this goes to the admissibility of
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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=== Page 1 ===
From:
To:
Subject: Accepted: Brass Meeting on Epstein
Date: Sat, 07 Dec 2019 01:05:03 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: draft letter to Netburn
Date: Wed, 22 Jul 2020 17:52:20 +0000
Attachments: 2020-07-22,_JE,_letter_to_Netburn_re_order_on_unsealing.docx
So I obviously had to do this pretty quickly today, and it doesn't help that Westlaw has been down all afternoon, but one
way or the other we gotta get something filed. Does either of you have a moment to take a look at this in the next hour
or so?
I'm sorry, I know you have something at 2:00! If the answer is no, totally understand, I can just pass it up
to
and
Thanks either way and talk soon.
EFTA00021916


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=== Page 1 ===
STATE
STATES
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 14, 2021
VIA CERTIFIED MAIL
Ghislaine Maxwell (Reg. No. 02879-509)
MDC Brooklyn
Metropolitan Detention Center
P.O. Box 329002
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
Enclosure
EFTA00020820


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Date: Mon, 06 Jul 2020 22:49:38 +0000
Inline-Images: image001.jpg
I know we chatted about this but just wanted to reply to say that this is indeed the last communication!
From:
Sent: Monday, July 06, 2020 17:55
To:
is
Subject: FW: Epstein investigation [FFW-DOCS.FID6003375]
Just checking that this is the last communication before I email her (unless you'd prefer to,
From:
Sent: Wednesday, March 11, 2020 9:46 PM
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us is
completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim this
makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be
possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in
changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just
completely beyond our control.
thank you,
From:
)
Sent: Thursday, March 05, 2020 13:13
To: Jill Greenfield
Cc: Louise Scott
i
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Just to clarify, would it be possible for you to provide us even a very general or high-level summary of what she has told
you? We ordinarily don't go into interviews completely blind when witnesses have counsel - and the Weinstein
investigation had a great number of problems that we have been able to avoid. And separately, we'll of course keep you
updated on our approval process as well.
EFTA00022307

=== Page 2 ===
thanks again,
From: Jill Greenfield
Sent: Thursday, March 05, 2020 04:20
To:
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Thanks
I am afraid that an attorney proffer will not be possible. I have been working with the DA in New York on the Weinstein
case and have simply offered up my clients to questions which has worked well.
I am of course happy to speak over the phone but it seems to me that you are better off getting the information first hand. If
you wish it may be sensible for you to initially have a call with my client?
My client has made a complaint to the Met police regarding a sexual assault by Jeffrey Epstein whilst in London and in the
employment of G Maxwell. Apart from the complaint itself, no further information has been provided to the police.
I appreciate the issue re coronavirus of course.
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Wednesday, March 4, 2020 5:04 PM
To: Jill Greenfield
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
That's great, thank you for letting us know, and we'll check on that right away and get back to you as soon as possible.
The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government
international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here
immediately.
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here - and we
talked about this on the phone as well - would be to get an attorney proffer about your understanding of generally what
information you expect your client will convey on the subjects we've spoken about? We completely understand that it's
best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us and the
EFTA00022308

=== Page 3 ===
witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have
that discussion? We could do as soon as tomorrow or Friday, or also next week.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, March 04, 2020 11:46
To:
Cc: Louise Scott
is
V.
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please?
Kind regards
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From:
Sent: Tuesday, March 3, 2020 11:17 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Jill,
We wanted to quickly follow up since I think you and I last spoke a little over a week ago-understand if you are still
discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be
useful, as always.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 17:09
To:
Cc: Kyle Phillips
>; Louise Scott
is
EFTA00022309

=== Page 4 ===
is
)
Subject: Re: Epstein investigation
Thanks
Understood
I will call tomorrow
Regards
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
Sent from my iPhone
On 22 Feb 2020, at 21:51,
)
wrote:
Jill,
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that
your client is open to speaking with us.
On your questions, we are certainly fine with the first two questions / requests - we're happy to meet with you and your
client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you
(and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and
then to take a break and have a more substantive discussion later on.
Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals
in addition to the witness and counsel in an interview-what does sometimes work is for someone who is providing
support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak
with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an
attorney then he of course could be in the interview in that role (with the only caveat that we would just want to
confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for
third parties (including counsel) to travel in connection with witness interviews, though - if it's preferable, we certainly
could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the
friend to be present? And we're happy to discuss any of this further by email or phone if that's useful - l'll be at my
desk for the next several hours and most of tomorrow, at
or we could also set a time to chat, whatever
would be helpful.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 13:55
EFTA00022310

=== Page 5 ===
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
That there be a morning meeting at which introductions with a discussion as to the investigation and my clients
involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist.
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to
be flown over to London. He is a US lawyer.
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Saturday, February 15, 2020 7:08 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
i
>;
Subject: RE: Epstein investigation
Understood - thanks very much.
From: Jill Greenfield
Sent: Saturday, February 15, 2020 07:22
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
)
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
EFTA00022311

=== Page 6 ===
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image003.jpg>
Sent from my iPhone
On 14 Feb 2020, at 21:43,
wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some
of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to
approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine what
topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that
would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as
we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no
problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up being
comfortable with that, and answered in person any questions she. We have done that previously, where we do the
talking rather than asking questions in an initial meeting, and that would of course be without any requirement for
anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able
to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in
approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client
were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or
victimization she experienced. We wrote in our first email that we would primarily be interested in talking about
topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as
always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet
the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a
discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment
and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in
particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell
you in advance if there came a time when we thought that might be important to address, and how we could facilitate
that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that
every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more
generally working with victims and working on cases involving sex offenses. We are proud of how we have been able
to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same
sensitive approach with your client as we have with the many other victims in this case who have spoken with us.
EFTA00022312

=== Page 7 ===
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our
process works, and answer any questions your client has in person, we would absolutely be happy to do that with no
obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address
the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate
your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
)
is
Subject: RE: Epstein investigation
Jill,
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're
of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up
those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I
can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any
follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
EFTA00022313

=== Page 8 ===
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
Many thanks
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
)
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her
trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would
be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and
his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked
EFTA00022314

=== Page 9 ===
directly for. That would broadly include how she came to be in contact with them, the nature and scope of her
employment, any instructions she was given relating to other women or girls, and just generally her experiences and
observations in interacting with them. We ordinarily would also be interested in understanding the general nature of
the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if
she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the
sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments
for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulated
by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, London
EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00022315


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c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: protective order and draft affidavit
Date: Tue, 28 Jul 2020 19:05:30 +0000
Attachments: 2020-07-25,_GM,_protective_order,_clean_version.docx;2020-07-
28,_GM,_affidavit_of_certification,_Rule_16,_protective_order.docx
And if you guys wouldn't mind taking a quick look at both, too, please? Just to make sure I haven't screwed any of this
up! Thank you!!
From:
)
Sent: Tuesday, July 28, 2020 15:04
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: protective order and draft affidavit
As promised. I've never done one of these affidavits before, so very happy for any suggestions on that in particular.
EFTA00021757


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c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
USANYS) [Contractor]"
Cc:
(USANYS)"
Subject: RE: financial exhibits
Date: Fri, 08 Oct 2021 13:26:24 +0000
Attachments: 500_Series - Financial_Exhibits.zip
Attached, thanks.
From:
Sent: Friday, October 8, 2021 8:59 AM
To:
(USANYS) [Contractor]
V.
(USANYS) [Contractor]
Cc:
(USANYS)
Subject: financial exhibits
Team, could you please send me a zip of the financial exhibits? It would be great if the file names of the exhibits just had
the GX number in them. I'm sending them to counsel for JP Morgan to discuss having a records custodian testify. Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020576


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c0:
=== Page 1 ===
From: "
To:
Cc:
"
Bcc: "USAHUB-USAJournal111"
Subject: Re: Brunel
Date: Wed, 20 Jan 2021 17:58:58 +0000
Embedded: Re:_Brunel.msg
Sender:
Subject: Re: Brunel
Message-Id: <0DD6CE38-7765-4C45-A91F-EC6C0C42C929@usa.doj.gov>
To:
Cc:
EFTA00020904


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=== Page 1 ===
From:
To:
Subject: call from attorney for David Rogers
Date: Tue, 16 Jul 2019 15:06:15 +0000
Importance: Normal
represents David Rogers, pilot for Epstein
-
served with a subpoena
Lankler has spoken with Rogers
Thoughts on where he's at? Rogers is more than happy to be cooperative, doesn't believe he has much significant
information
Before 2006, instances where people on the plane were a minor, after 2006, doesn't believe that was the case anymore
-
cooperated with the FBI as part of the Florida investigations
-
beyond that doesn't believe he has additional useful information
-
he flies with a co-pilot, no staff / stewardess
-
everybody appears to be an adult, post-2006
EFTA00021440


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c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: FW: Ghislaine Maxwell (USMS No. 02879-509)
Date: Mon, 06 Jul 2020 23:50:09 +0000
Good evening,
I received an out of office message in response to the below email. Would someone be able to assist with this matter,
please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, July 6, 2020 7:49 PM
To:
Cc:
is
Subject: Ghislaine Maxwell (USMS No. 02879-509)
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to file a letter
by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but they have not been
able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her lawyers this evening, please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00021832


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c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Cc:
)"
)"
=
)"
Subject: Re: a letter to the editor
Date: Tue, 26 Nov 2019 03:03:47 +0000
I did not see that coming.
Sent from my iPhone
On Nov 25, 2019, at 9:57 PM,
(USANYS)
wrote:
Wow
Sent from my iPhone
On Nov 25, 2019, at 6:43 PM,
)
wrote:
https://www.nytimes.com/2019/11/24/opinion/letters/jeffrey-epstein-prisons.html
Assistant U.S. Attorney
Southern District of New York
EFTA00020661


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
NOTICE OF MOTION
GHISLAINE MAXWELL,
:
Defendant.
:
ORAL ARGUMENT REQUESTED
:
:
X
DEFENDANT GHISLAINE MAXWELL'S NOTICE OF MOTION TO DISMISS
COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT BECAUSE THE
ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW
(Pretrial Motion # 4)
PLEASE TAKE NOTICE that, upon the accompanying memorandum of law and
exhibits, Defendant Ghislaine Maxwell, through counsel, hereby moves to dismiss Counts Five
and Six of the Superseding Indictment because the alleged misstatements are not perjurious as a
matter of law.
Dated: January 25, 2021
New York, New York
EFTA00021021

=== Page 2 ===
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303-831-7364
Mark S. Cohen
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
Phone: 212-957-7600
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
1
EFTA00021022


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=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: FW: Epstein investigation
Date: Wed, 07 Aug 2019 15:51:22 +0000
Inline-Images: image001.jpg; image002.jpg; image003.png
Bachner just called and apologized, he was on his way to the office from a meeting that ran late. He said he'd email us
times that work for him this afternoon so that we can reschedule.
From:
Sent: Wednesday, August 7, 2019 11:35 AM
To: Michael Bachner
Cc:
is
Subject: RE: Epstein investigation
Hi Michael,
We just tried your office-please let us know if we should reschedule. Thanks.
From: Michael Bachner
Sent: Thursday, August 1, 2019 3:41 PM
To:
Cc:
is
Subject: RE: Epstein investigation /
11:30?
Michael Bachner
Bachner & Associates, P.C.
Partner
39 Broadway, Suite 1610
NY NY 10006
AMERICAN COLLEGE EGE
OF
TRIAL
LAWYERS
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
EFTA00021750

=== Page 2 ===
www.bhlawfirm.com
RATED BY
Super Lawyers
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
[mailto:
Sent: Thursday, August 1, 2019 3:11 PM
To: Michael Bachner
Cc:
is
Subject: RE: Epstein investigation /
Mike,
That would work -- we could do any time between 11 a.m. and 3 p.m. this coming Wednesday. What time should we put
in the calendar?
thanks,
From: Michael Bachner
Sent: Thursday, August 01, 2019 14:48
To:
Cc:
is
Subject: RE: Epstein investigation /
Wednesday ?
Michael Bachner
Bachner & Associates, P.C.
Partner
39 Broadway, Suite 1610
NY NY 10006
AMERICAN
COLLEGE
OF
LAWYERS
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
EFTA00021751

=== Page 3 ===
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
RATED BY
Super Lawyers
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally
privileged. If you are not the intended recipient, you are hereby notified that any retention,
dissemination, distribution, or copying of this communication is strictly prohibited. Please reply to the
sender that you have received the message in error and then delete it. Thank you.
From:
) [mailto:
Sent: Wednesday, July 31, 2019 7:39 PM
To: Michael Bachner
Cc:
is
Subject: RE: Epstein investigation
/
Michael,
We wanted to follow up on our previous discussions and our meeting the week before last. Is there a good time for you
early next week to discuss status?
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021752


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: GM -
Date: Sat, 09 Oct 2021 04:10:34 +0000
Attachments:
.pdf; Pages_from_PB_76-2.pdf;
2020.07.02_050D-NY-3027571_0000413.pdf
We had mentioned to
wanting to chat through a few things tomorrow. One of the topics we would like to chat about
is
who we spoke with today. I'm attaching the notes from today, as well as a report on her tipline call and
pages from the PBPD report we discussed earlier this week.
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:
EFTA00022645


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=== Page 1 ===
From:
To:
Subject: FW: Epstein Client Meetings
Date: Thu, 10 Oct 2019 18:18:00 +0000
Inline-Images: image001.png
We have left our schedule open for interviews so that will work for us as well.
On Oct 10, 2019 2:15 PM,
wrote:
See below. I'm available on 10/23 after 2pm and all day on 10/24. What works for you guys?
From: Brittany Henderson
Sent: Thursday, October 10, 2019 2:08 PM
To:
is
>;
Cc: Brad Edwards
Subject: Epstein Client Meetings
We have been coordinating with
to schedule the following victim interviews for October 23 & 24:
If possible, the morning on October 24 works best for
would prefer the 23 to minimize her travel
into the City.
and
are available either day.
Let us know what works best for you.
EDWARDS
POTTINGER LLC
Brittany Henderson
Trial Attorney
www.epllc.com
EFTA00021331


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=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
Bec: "USAHUB-USAJournal111"
Subject: RE: Request re Ghisliane Maxwell
Date: Fri, 08 Jan 2021 17:06:18 +0000
Embedded: RE:_Request_re_Ghisliane_Maxwell.msg
Sender:
Subject: RE: Request re Ghisliane Maxwell
Message-Id:
<BN3P110MB03390554184E44B65DBCE05292AE0@BN3P110MB0339.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
Cc:
Cc:
EFTA00020903


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: co conspirator question transcript
Date: Fri, 07 Feb 2020 17:36:20 +0000
From:
(USANYS) [Contractor]
Sent: Friday, February 7, 2020 12:22 PM
To:
(USANYS)
Subject: CO conspirator question transcript
Q: When Jeffrey Epstein died, a lot of people asked what's next? Is the government going to hold people who are accused
of helping him recruit these younger girls, participated in this, can you give us a little bit of an update of where your office
is in this investigation?
A: Well, I'll note that the original charges against Jeffrey Epstein contained a conspiracy charge and we alleged that there
were conspirators involved. And Jeffrey Epstein couldn't have done what he did without the assistance of others and I can
assure you that our investigation is moving forward.
EFTA00020571


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=== Page 1 ===
Epstein Accusations (from Press Reporting)
Name
Accusation
Location
Source(s)
Recruited by unidentified female brunette in her 20s outside of her
New York
https://www.nbcnews.com/news/us-news/new-jeffrey-epstein-accuser-
he-raped-me-when-i-was-n1028011
high school in the fall of 2001, when she was 14.
Joint visits with unidentified female for a month. Then solo trips to
Epstein's house.
Regularly gave Epstein massages. Sometimes he masturbated.
Manipulated into stripping down to her panties during the massages.
Paid $300 each time.
"He would also like when I would play with his nipples. He used to get
turned on by that. And then he would finish himself off and then that
would be the end of it."
Over the next several months,
visits followed a familiar
routine. Epstein's secretary would contact her by email, beeper or
her family's landline to set up a meeting,
said. When she
arrived, she'd be escorted to the elevator and head straight to the
massage room. Once or twice a week for a year.
In the fall of 2002, Epstein said "Why don't we try something a little
bit different?" she recalls him saying. "Why don't you do the massage
on top of me?"
said she told him that she wanted to "stick to
the normal routine," but she ultimately removed her underwear. He
fondled her privates, she said. Then he "brought me up there and it
was very aggressive, it was forceful," she said.
said she was
terrified and told him to stop. "He was like, 'It's okay. You're fine.
You're not doing anything wrong," added
who said he did not
use a condom. After it was over,
said, she rushed out of the
house angry and shaken.
Met Epstein in 1997 in Santa Monica, LA.
Los Angeles
https://www.rollingstone.com/culture/culture-news/jeffrey-epstein-
victorias-secret-
864095/
Took her back to his hotel for a Victoria's Secret tryout. There he
groped her buttocks against her will, and told her to undress.
Recruited by
and
in South Africa when she was
Cape Town,
Boies Schiller Lawsuit
20.
NYC, Paris,
Within two weeks,
arrived in New York. A car picked her up
NM and
from the airport and brought her to an apartment building on 66th
USVI
Street, where Epstein housed some of the other models who he was
abusing. But
was not there for long. Shortly after arriving at
the apartment,
another one of Epstein's co-
conspirators, called and told
that
EFTA00022133

=== Page 2 ===
Name
Accusation
Location
Source(s)
was going to the Caribbean.
did not understand why
she was traveling to the Caribbean so soon after arriving in New York
City, but hoped it was for a modeling job.
was taken on Epstein's private plane. During the flight,
Epstein began sexually touching
leg. She felt trapped and
terrified, and feared that she would be killed.
They arrived at Epstein's home in the Virgin Islands. Epstein's abuse
of
there began when
sent
to Epstein's room to
massage him. For the rest of the trip, Epstein repeatedly raped
by forcible compulsion.
repeatedly sent
to
Epstein's room, where he would touch her, use massage devices on
her, force her to perform oral sex on him, and sexually force himself
on her.
also witnessed another young girl performing oral sex
on Epstein in front of
while they were watching a movie.
Epstein's abuse of
lasted for years. Epstein forced her to
travel to the United States many times to see Epstein and be
subjected to repeated sexual abuse for one to two weeks at a time,
sometimes staying in his New York apartment.
was also forced to travel to Epstein's home in Paris where she
had to stay with Ghislaine Maxwell, one of Epstein's main recruiters
of young females, and where
forced her to be
photographed nude for Epstein. During that trip,
witnessed
that young females were on call to sexually pleasure Epstein.
final trip to the United States was in 2004. She flew to see
Epstein at his New Mexico ranch, called "Zorro Ranch." Epstein
abused
at Zorro Ranch.
Epstein attempted to keep in contact with
through e-mail
over the years. For example, in 2016, Epstein e-mailed
to ask
if she knew
another woman who was a victim of
Epstein's sex trafficking scheme. In June 2019, only two months
before his death, Epstein sent
an e-mail asking her to send
him nude photographs.
Recruited by a woman named Rena in the fall of 2000
New York
Hearing Transcript
Shown into a room with Alan Dershowitz and Epstein. Deshowitz left
https://www.miamiherald.com/news/state/florida/article235247637.html
the room. Rena and Epstein took off their clothes.
"sexually assaulted by both Rena and Epstein"
"I remember thinking 'I've never done this before, what's going on, I
just. don't know"
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=== Page 3 ===
Name
Accusation
Location
Source(s)
16 when she met Epstein in 2000
New York
https://nypost.com/2007/10/18/i-was-teen-prey-of-pervert-tycoon/
Told her that he could make her a Victoria's secret model.
Epstein took off his robe and started pushing her head toward his
groin, saying, "You know what to do. If you want me to help you then
you have to help me,"
When he was finished, he allegedly told her to come back sometime
"with her 14-, 15- and 16-year-old girlfriends." "I love girls your age,"
"I love how young you are. You have a tight butt like a baby," he's
quoted as saying.
He also told her that "I would love for you to come with me to
Thailand to pick up other girls your age" - and even "took preliminary
steps" to take her there, the suit claims.
Recruited by Maxwell
Recruitment
https://www.npr.org/2019/09/02/756823299,
describes-
coming-forward-as-epstein-accuser
21 when she met Epstein. Studying to be a massage therapist. Flown
in NYC, first
https://www.nbcnews.com/news/us-news/how-british-teen-model-was-
meet in PB
lured-jeffrey-epstein-s-web-n1056901
down to PB.
https://www.nbcnews.com/news/us-news/how-british-teen-model-was-
told her Jeffrey wanted a massage. In massage room, he
First rape in
lured-jeffrey-epstein-s-web-n1056901
Hearing transcript
immediately stripped and asked
a lot of questions.
USVI,
Flipped onto his back and asked if he could touch himself. I gave him
the OK to touch himself because I didn't know what else to say or do
in that moment. And he finished and jumped off the table and got in
the shower and said, OK, that's all now; thank you. And I left the
room, you know, with my head spinning, trying to figure out what the
hell just happened.
Raped a few months later after a handful of massage sessions.
In USVI, Tugged her towards bed during massage, unbuttoning her
shorts, pulling body onto his already naked body. She said "please
stop". He proceeded to rape her.
"abuse would continue for the next three years"
Raped 3-4 times total.
17 at the time (2002)
NYC, NM
https://nypost.com/2019/11/21/epstein-accuser-says-she-was-kicked-
out-over-her-eating-disorder/
Introduced in LA - Flew her to NM. During a massage, he fondled her
PB, USVI,
https://heavy.com/news/2019/11/
genitals.
Paris
"For the next two years, Epstein flew her around the world on his
private jets and repeatedly raped and molested her at his homes in
New York, Florida, the US Virgin Islands and Paris"
Epstein raped her while she was sleeping at his Florida home in
December 2002. He allegedly flew her out to Paris in 2003 shortly
after her semester abroad ended and raped her again as she slept.
EFTA00022135

=== Page 4 ===
Name
Accusation
Location
Source(s)
"Virtually every few days, Epstein would bring
to a different
home of his, including his Manhattan townhouse and throughout the
country, where he continued to sexually assault her on a frequent
basis."
says Epstein arranged for her to live in an apartment at 301 E.
66th St. in 2004 - just blocks from his Manhattan mansion.
Epstein tried to farm her out to other high-powered men
Rubbed hand & leg in movie theatre in NYC
NYC & NM
NYT Daily + Article
Foot massages in NM with Maxwell, pointers on how to do it how
https://www.nytimes.com/2019/08/26/us/epstein
sisters-
maxwell.html
Epstein likes it
Another round of movie theatre petting/touching in NM
Epstein climbs into bed with
spooning + touching
Maxwell gives her a nude massage. Epstein does not participate, but
"could feel his presence"
On bed with Epstein & Maxwell - asked to give foot massage
Ohio
NYT Daily + Article
https://www.nytimes.com/2019/08/26/us/epstein-
sisters-
Between the two of them- - they both started groping breasts,
maxwell.html
commenting on her features, twisting her nipples
Afraid of rape, ran away
Nude photos missing
Met in London
Recruited in
https://www.nbcnews.com/news/us-news/how-british-teen-model-was-
lured-jeffrey-epstein-s-web-n1056901
Was raped numerous times over the course of several years - not
London,
many details
abused in
Grooming/Recruitment: "It wasn't zero to 100 in one day. It was
USVI, NYC,
introduced piecemeal, along with constant emotional, financial
Paris
reinforcement that this was the path, the only path"
Recruited by Maxwell from Mar-a-Lago in 2000
Recruitment
https://edition.cnn.com/2019/12/02/uk/prince-andrew
panorama-intl-gbr/index.html
Maxwell taught her how to give Epstein massages, oral sex, and
at Mar-a-
https://www.youtube.com/watch?v=qLAzubOpOtg
Lago. Sex
https://www.washingtonpost.com/politics/she-was-shaking-court-filings-
sexual toys.
describe-system-jeffrey-epstein-allegedl-used-to-procure-
She "had to have sex with Epstein many times"
with Epstein
girls/2019/08/09/83093f3e-babe-11e9-bad6-609f75bfd97f_story.html
https://nypost.com/2019/12/02/sex-with-prince-andrew-was-quick-and-
Forced to recruit other girls
in NYC, PB,
disgusting-
roberts
"In 2001,
alleges that Epstein brought her to London, where
NM, and
https://www.thesun.co.uk/news/9966496/
jeffrey-
epstein-sex-slave-prince-andrew-vodka/
she was introduced to Prince Andrew and went dancing at a
USVI.
https://www.vanityfair.com/news/2019/08/new-details-in-unsealed-
jeffrey-epstein-documents
nightclub with Epstein, his then-girlfriend Ghislaine Maxwell and the
prince." Andrew ordered her a vodka and asked her to dance.
Prince
Raped by Prince Andrew at Maxwell's in London. Instructed by
Andrew in
Maxwell to "do for Andrew what I do for Jeffrey". "It didn't last very
London,
long. The whole thing, procedure - - it was disgusting," Was in the
NYC, and
USVI
EFTA00022136

=== Page 5 ===
Name
Accusation
Location
Source(s)
bathroom and bedroom. "He wasn't mean or anything," the now-36-
year-old mom of three said of the prince. "He got up and said thanks
and walked out. I sat there in bed and felt ashamed and dirty."
Had sex with Prince Andrew 3 times.
Epstein directed her to have sex with Glen Dubin
also alleges Epstein and Maxwell told her to have sex with
former New Mexico governor Bill Richardson; former Democratic
Senate Majority Leader George Mitchell; the late MIT computer
scientist Marvin Minsky; and MC2 model agency cofounder Jean Luc
Brunel, as well as an unnamed "prince," "foreign president," and
owner of "a French hotel chain."
previously alleged she had
been forced by Epstein and Maxwell to have sex with lawyer Alan
Dershowitz and Britain's Prince Andrew.
Had sex with Dershowitz at least 6 times, aged 16-19
In 2007 Maxwell and Epstein (separately) called her to ask her to
keep quiet.
Recruited by
in LA when she was 22.
NYC
Hearing transcript
About two weeks after her initial interview with
told
Boies Schiller Lawsuit
that the couple wanted to fly her to New York for another
interview. The couple bought her a ticket for a flight from California
to New York City.
Gave Maxwell a massage. Maxwell told her she'd be massaging
Epstein. She then paid
$100 for the massage and told her to
give Epstein "whatever he wants" during his massage because
Epstein "always gets what he wants."
Epstein asked
to sit down and began asking her personal
questions. He eventually asked her to give him a foot massage. She
agreed and placed his foot in her lap so that she could begin the
massage. As
began massaging Epstein's foot, he started
pressing his foot against intimate parts of
body.
became uncomfortable, adjusted her position, and moved Epstein's
foot up to keep it away from her body. But Epstein continued pushing
his foot into her body.
While still on the couch in Epstein's office, Epstein got close to
grabbed her chin with his hand, turned her face towards him,
and said that he knew he could trust
Specifically, he said, "I
know I can always trust a woman who shows her gums when she
smiles." Epstein's actions terrified
EFTA00022137

=== Page 6 ===
Name
Accusation
Location
Source(s)
Epstein then got up to walk
out of the room.
was
walking in front of Epstein when he abruptly grabbed her and
proceeded to sexually assault her against her will.
stopped
walking and Epstein then forcefully grabbed her and sexually
assaulted her again.
was frozen with shock and fear. Once
Epstein released her she continued walking towards the front door of
the mansion.
Just before
stepped out the front door, Epstein grabbed her
buttocks and said, "Don't do anything I wouldn't do."
proceeded to leave Epstein's mansion, and went back to the 66th
Street apartment building.
Met when she was 14
Palm Beach
https://www.youtube.com/watch?v=1jDP2W9COsU
Massages. Came out in a towel. Told her to undress to her
underwear. Masturbated himself. Asked her to play with his nipples
and he did the same.
Paid $200 each time
16 years old at the time, recruited by another high school girl to give
Unclear
https://www.youtube.com/watch?v=XShjryy8014
https://www.youtube.com/watch?v=1jDP2W9COsU
Epstein a massage.
During massage, he asked her to rub his back. Kept asking to go lower
and lower. Kept talking to her about her sex life.
Masturbated in front of her.
Tried to put his finger in her underwear, and she jumped back. He
continued feeling her genitals, but said "just on the outside"
Epstein raped her in 1993
NYC
https://nypost.com/2019/11/27/ex-model
accuses-jeffrey-
epstein-of-1993-rape/
"He said, 'If you tell anybody anything I'll crush whatever career you
might have,' or something like that. He was just so mean so quickly.
"It literally went from awkward to mean to rape so fast," she told the
UK paper.
She recalled how he made her feel "embarrassed and ashamed and
stupid" - and that he got "irritated, almost angry" when she told
him she was 21.
"He said something like, 'You're too, you're too old. You're getting
too old for this. What are you doing?"
22 at the time (2006)
USVI
https://www.telegraph.co.uk/news/2019/09/13/prosecutors-must-probe-
jeffrey-epsteins-trafficking-network/amp/
Recruited by an unidentified female.
Went to the movies, then was invited to USVI. There was an orgy on
the plane, but she did not participate.
On the island, she was called in for massages.
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=== Page 7 ===
Name
Accusation
Location
Source(s)
Ultimately made a series of trips to the island. Maxwell was usually
present.
"There were some days I was raped three times a day. And then he
would rape others."
"We had to be always around the house, so it would be easy to get
there. For him and his friends, who he lent us out to.
"In six months I never saw him do a day's work. I never saw him
work. He was literally sexually abusing us all day long."
Lived in an UES apartment paid for by Epstein.
In early 2007 Miss
was sent to South Africa to look for a
personal assistant for Epstein - he insisted that she had to be 18, and
had to be found through a modelling agency.
said under oath that Maxwell approached her on
New York,
https://www.vanityfair.com/news/2019/08/new-details-in-unsealed-
jeffrey-epstein-documents
her college campus with the promise of a job answering Epstein's
UK
https://www.thesun.co.uk/news/9764107
claims-
against-jeffrey-epstein-prince-andrew/
phones, but within a day she was coerced into having sex with
https://heavy.com/news/2019/11,
Epstein. Epstein once told her "he needed to have three orgasms a
day. It was biological, like eating," she recalled.
Groped by Prince Andrew during visit to the UK with Epstein. "I just
remember someone suggesting a photo, and they told us to go get on
the couch," she said in court documents. "And so Andrew and
sat on the couch, and they put the puppet, the puppet on her
lap. "And so then I sat on Andrew's lap, and I believe on my own
volition, and they took the puppet's hands and put it on
breast, and so Andrew put his on mine."
21 at the time (2004)
New York
https://nypost.com/2019/07/14/inside-the-victorias-secret-pipeline-to-
jeffrey-epstein/
Greeted at the door by Maxwell
As
talked about her experience in halting English, she said Epstein
moved to the massage table and began to remove his clothes. He was
naked on the table and asked her to approach. He handed her a
vibrator. "I just grabbed the vibrator and threw it at his head". She
ran out of the room.
Met when she was 14
Unclear
https://www.youtube.com/watch?v=XShjryv80t4
https://nypost.com/2019/07/08/jefrey-epstein-accuser-i-was-14-years-
Massaged Epstein for 30 minutes. Epstein asked her to take her
old-and-still-in-braces-when-abuse-began/
clothes off to get comfortable, but can leave bra and panties on. She
stood next to him as he touched her and masturbated.
Epstein asked her to bring other high school girls. For every girl, he'd
pay her $200.
EFTA00022139

=== Page 8 ===
Name
Accusation
Location
Source(s)
"By the time I was 16, I had probably brought him 70 to 80 girls who
were all 14 and 15 years old. He was involved in my life for years."
"He told me he wanted them as young as I could find them" "If I had
a girl to bring him at breakfast, lunch and dinner, then that's how
many times I would go a day. He wanted as many girls as I could get
him. It was never enough."
Jane Doe 1
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Brad
Edwards)
Jane Doe 2
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Brad
Edwards)
Jane Doe 3
"sexually assaulted by Epstein"
New York
Hearing Transcript
(Brad
Recruited by unidentified female
Edwards)
Jane Doe 4
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Brad
Edwards)
Jane Doe 5
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Brad
Edwards)
Jane Doe 6
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Lisa Bloom)
Jane Doe 7
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Lisa Bloom)
Jane Doe 8
At hearing - did not specifically detail abuse
n/a
Hearing Transcript
(Lisa Bloom)
Jane Doe 9
"Sexually molested by him for many hours"
New Mexico
Hearing Transcript
(Gloria Allred)
"positioned me by laying me on his floor so that I was confronted by
all the framed photographs on his dresser of him smiling with
wealthy celebrities and politicians."
"After he finished with me, he told me to describe in detail how good
my first sexual experience felt."
Jane Doe 10
Recruited by unidentified female
New Mexico
Hearing Transcript
(Gloria Allred)
Epstein asked if she would give him a massage.
Over the course of four visits, eventually progressed to "forced oral
copulation"
Paid money
EFTA00022140

=== Page 9 ===
Name
Accusation
Location
Source(s)
Jane Doe 11
Raped by Epstein at 16 years old
New York
Hearing Transcript
(Gloria Allred)
Innocent massage turned sexual almost immediately
"Here, come. Come help me with a kink in my shoulder while we
finish our discussion." A large vibrator and a couple of hundred
dollars, disgust and dirty secret, more praise and imparted wisdom
from a godlike figure, a deliberate diabolical depression of grooming
and submission for his pleasure and release. Even if I resisted, I was
no match for him. I felt powerless, ashamed, and embarrassed. I
wanted to vomit remembering these moments."
"washed my entire body compulsively in the shower"
"He forcefully penetrated me. I was numb. There was pain, but his
use of the vibrator and his fingers in previous sessions with me had
left a black hole-like void between my legs. I protested, but he forced
my face into the bed to stifle my cries. That was my first time."
Paid a few hundred dollars
Jane Doe 12
Recruited by unidentified woman
New York
Hearing Transcript
(Gloria Allred)
In Epstein mansion, he had a white robe on, then he took it off and
locked the door.
Got close to her, and touched her genitals. She refused him. He went
to the massage table and showed her the vibrator.
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To: "
(USANYS)"
Subject: RE:
Date: Tue, 14 Jul 2020 21:43:45 +0000
All set. I'll save everything here as it comes in.
\InReEpsteinDeath-
\FBI Case File
Original Message
From:
USANYS)
Sent: Tuesday, July 14, 2020 5:35 PM
To:
(USANYS) [Contractor]
Subject: FW:
For MCC shared drive - we are getting the FBI case file, so maybe put in a folder titled that? We'll need to
review all of these 302s and make discovery decisions.
Original Message
From:
(NY) (FBI)
Sent: Tuesday, July 14, 2020 2:51 PM
To:
(USANYS)
Subject:
Hey
When looking through my case file, this is where
documented the phone number and last call made by
Epstein. Let me know if you need anything else
Special Agent
FBI New York Field Office
Violent Crimes Task Force
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=== Page 1 ===
Event: Accepted: Epstein Press Meeting
Start Date: 2019-07-01 20:00:00 +0000
End Date: 2019-07-01 21:00:00 +0000
Organizer: Berman, Geoffrey (USANYS)
Location: 8th Floor Library
Class: X-PERSONAL
Comment:
Date Created: 2019-07-01 02:59:04 +0000
Date Modified: 2019-07-01 02:59:04 +0000
Priority: 5
DTSTAMP: 2019-07-01 02:57:06 +0000
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=== Page 1 ===
From:
To:
Subject: Brass materials
Date: Wed, 14 Aug 2019 23:14:44 +0000
Attachments: Brass_Presentation_Outline.docx; 2019.08.14_Brass_Presentation_PPT.pptx
This is super high level. Do you want to add in your stuff then we can send to the chiefs?
l'll fill this in more for my own purposes but they don't need that tonight.
Assistant United States Attorney
Southern District of New York
Tel:
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=== Page 1 ===
From:
"
USANYS)"
To:
"
USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: FW: Jeffrey Epstein's final days at NYC jail revealed by inmates - New York Daily News
Date: Mon, 28 Dec 2020 18:41:23 +0000
Just wanted to make sure you were aware of this.
Original Message
From:
(USANYS) [Contractor]
Sent: Monday, December 28, 2020 1:02 PM
To:
(USANYS)
(USANYS)
(USANYS)
(USANYS)
(USANYS)
Subject: Jeffrey Epstein's final days at NYC jail revealed by inmates = New York Daily News
Here's the Daily News story on Efrain Reyes and Jeffrey Epstein.
https://www.nydailynews.com/new-york/ny-epstein-mcc-suicide-20201228-fk2h7hzynzburdqwb44jydllnq-story.html
U.S. Attorney's Office, SDNY
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Epstein FOIA Updates
Date: Tue, 23 Nov 2021 17:18:15 +0000
Got it. Thank you!
From:
(USANYS)
Sent: Tuesday, November 23, 2021 12:16 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Re: Epstein FOIA Updates
Those are the addresses I have for him. I would try Stacey, his lawyer. She is usually very responsive. Thanks for handling
this
On Nov 23, 2021, at 11:50 AM,
(USANYS)
wrote:
Hi Public Corruption Chiefs,
FYI, since the Times article came out today about Epstein's incarceration and death, BOP has been receiving multiple
new requests for the records released in the FOIA matter (ABC, CNN, MuckRack). BOP plans to respond to those
requests quickly and release the same records.
One minor wrinkle: the FOIA specialist at BOP has tried to contact Mark Epstein a couple times regarding his
communications from about a month ago. But so far he has not responded to her. She has asked if we have contact info
for him. What I have is this phone number
and these emails Mark Epstein
> and
STACEY RICHMAN
>. I am going to confirm BOP has these, but please let me know if there is
some other way to contact him.
Thanks,
Assistant United States Attorney
White Plains, NY 10601
Telephone:
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=== Page 1 ===
From:
)"
To: Jeff Pagliuca <jpagliuca@hmflaw.com>
Cc:
)"
>, Nicole Simmons
<nsimmons@hmflaw.com>,
)"
"CEverdell@CohenGresser.com" <CEverdell@cohengresser.com>,
"mcohen@CohenGresser.com" <mcohen@cohengresser.com>, Laura Menninger
<Imenninger@hmflaw.com>
Subject: RE: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 20:51:58 +0000
Attachments: 2020-08-12_letter_to_GM_counsel_re_discovery.pdf
Jeff,
Attached please find the Government's response to your August 9, 2020 letter.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Tuesday, August 11, 2020 11:45 PM
To:
)
Cc:
>; Nicole Simmons <nsimmons@hmflaw.com>;
)
>; ; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
<Imenninger@hmflaw.com>
Subject: Re: Letter regarding discovery attached.
I'm not sure I can wait for a decision until Thursday. I will discuss with my colleagues and attempt to confer with the
Government by phone tomorrow. Absent any additional information from the government you are not leaving me with
any realistic options and I will probably need to simply advise Judge Nathan that the government's position is forthcoming
but because we learned about the information on Friday and the Circuit's tight schedule we could not wait any longer.
A phone call tomorrow would be appreciated.
Jeff
EFTA00021898

=== Page 2 ===
On Aug 11, 2020, at 9:07 PM,
wrote:
Jeff,
We are still considering your request, and we will reach out when we are prepared to provide you with our response,
which will be no later than Thursday, August 13th.
Best,
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Tuesday, August 11, 2020 7:28 PM
To:
)
>
Cc:
>; Nicole Simmons <nsimmons@hmflaw.com>;
>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com; Laura Menninger
<Imenninger@hmflaw.com>
Subject: Re: Letter regarding discovery attached.
Looks like our email is back up. As indicated in the gmail email I would like to discuss your position by phone tomorrow. I
am available any time.
Jeff
On Aug 11, 2020, at 12:19 PM,
wrote:
Good afternoon,
We will provide you with our response by this Thursday, August 13th. We will, of course, send the response sooner if
we are able.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, August 10, 2020 5:28 PM
To: Nicole Simmons <nsimmons@hmflaw.com>;
is
-
>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
EFTA00021899

=== Page 3 ===
Cc: Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>
Subject: RE: Letter regarding discovery attached.
Good afternoon,
We are in receipt of the email and letter. We will respond as soon as we are able.
Regards,
Alex.
Assistant U.S. Attorney
Southern District of New York
212.637.2415
From: Nicole Simmons <nsimmons@hmflaw.com>
Sent: Monday, August 10, 2020 16:18
To:
)
is
)
V.
)
>; CEverdell@CohenGresser.com; mcohen@CohenGresser.com
Cc: Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>
Subject: FW: Letter regarding discovery attached.
Dear Counsel,
At the request of Jeffrey Pagliuca please see the attached letter. Our firm is currently experiencing technical issues with
our email system. If you would please kindly confirm receipt of this email and the attachment it would be greatly
appreciated.
Thank you,
Nicole
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Sunday, August 09, 2020 4:56 PM
To:
)'
i
;
)
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
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
<image001.jpg>
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
EFTA00021900

=== Page 4 ===
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
EFTA00021901


c1: EFTA00021911
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021911.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
)"
Subject: FW: Marshals Intake Form
Date: Wed, 22 Jul 2020 21:01:10 +0000
Attachments: Maxwell_JABS.pdf
could you please add this to the share and to the initial discovery production for Maxwell? Thanks.
From: Rosenman, Jeremy (USANYS) <JRosenman@usa.doj.gov>
Sent: Wednesday, July 22, 2020 17:00
To:
>; USANYS-INVESTIGATORS
Subject: RE: Marshals Intake Form
See attached.
From:
)
Sent: Wednesday, July 22, 2020 4:46 PM
To: USANYS-INVESTIGATORS
Subject: Marshals Intake Form
Please process the following:
Requestor's Phone Number:
Name / Alias(es): Ghislaine Maxwell
Court Number: 20 Cr. 330 (AJN)
USAO Number: 2018R01618
USMS Number: 02879-509
Arrest Date: 07/02/20
Date of Birth:
Documents: Email
Photo:
Email
Remarks:
EFTA00021911


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022017.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
)"
Subject: FW: Maxwell Suppression Opinion
Date: Mon, 28 Jun 2021 14:15:58 +0000
Attachments: 20cr330_Sealed_Opinion_&_Order_6.25.21.pdf;20cr330_Order_625.21.pdf
EFTA00022017


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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Epstein investigation
/
Date: Fri, 12 Jul 2019 01:00:14 +0000
Importance: Normal
Inline-Images: image001.jpg
yah
From:
Sent: Thursday, July 11, 2019 20:59
To:
Cc:
Subject: FW: Epstein investigation
/
have a tight schedule already next week, so they'd prefer to do this at 6pm on Tuesday 7/16. That's fine
with
and me. Work for you? If so, l'll suggest.
From: Michael Bachner
Sent: Thursday, July 11, 2019 12:26 PM
To:
Cc:
is
Subject: Re: Epstein investigation
/
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in my office on the
16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the morning if that works.
Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
EFTA00020793

=== Page 2 ===
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is
intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or
employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination,
distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by
error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email
should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner
wrote:
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is
intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or
employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination,
distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by
error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email
should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:08 AM,
)
wrote:
Mike,
I think it would be useful to get a better understanding of your position-it would be helpful for us to know, for
example, how much time you propose to take to evaluate matters, and whether we can provide any additional
information that might be useful for that process of evaluation. That likely will affect our determination regarding the
grand jury appearance, at which we would expect, were we to cal
to ask her a number of questions we
would expect to argue to the court do not implicate a fifth amendment privilege-i.e., that she couldn't simply blanket
invoke. Would it be useful to discuss via phone?
thanks,
From: Michael Bachner
Sent: Wednesday, July 10, 2019 10:25
EFTA00020794

=== Page 3 ===
To:
Cc:
Subject: Re: Epstein investigation
Dear Counsel:
I met with
and I need time to evaluate matters. Regarding the subpoena to testify before the Grand Jury
on
we hereby notify you that if called as a witness
vould invoke her Fifth Amendment privilege
against compelled self-incrimination. Please let me know if you will require her to invoke in person or whether this
communication suffices and no appertaining will be required.
Yours truly,
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
"WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information, which
is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or
employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination,
distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by
error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email
should be construed as a legal opinion or tax advice.
On Jul 9, 2019, at 11:43 AM,
wrote:
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional information
and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to
reach out to any of us at any time; we're all available via email or at the following phone numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in Florida,
and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a time to
speak again after you're able to confer with
EFTA00020795

=== Page 4 ===
thank you,
Assistant U.S. Attorney
Southern District of New York
<blank proffer agreement.pdf>
<Epstein NPA, dated 2007-09-24.pdf>
EFTA00020796


c1: EFTA00023121
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023121.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Laura Menninger
Jeff Pagliuca
Christian Everdell
'BOBBI C STERNHEIM'
Subject: US V. Maxwell, 20 CR 330 (AJN) - Reply in support of Government's Motions in Limine
Date: Thu, 28 Oct 2021 03:49:27 +0000
Attachments: Govt_Reply_Brief_[unredacted].pdf; Govt_Reply_Brief_[proposed_redactions].pdf
Good evening,
Attached please find the Government's reply in support of its motions in limine in the above-captioned case. Pursuant to
the Court's order, the Government will file a redacted version on the public docket on Friday, October 29.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00023121


c1: EFTA00020668
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020668.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Weinstein, Marc A."
, Andrew Tomback
Cc:
)"
)"
Subject: RE: SDNY investigation
Date: Mon, 27 Jul 2020 14:40:53 +0000
Marc,
Received, and thank you.
Best,
From: Weinstein, Marc A.
Sent: Monday, July 27, 2020 10:22
To:
>; Andrew Tomback
Cc:
is
Subject: RE: SDNY investigation
We are in receipt of your July 26, 2020 letter. On behalf of the Co-Executors of the Estate of Jeffrey E. Epstein, we can
confirm the following: (i) Section 2.5(B) of The 1953 Trust has not been and will not be used by the Co-Executors to
suggest that any current or former employee who chooses to meet or provide information to law enforcement as part of
any ongoing investigation will be retaliated against in any way, or will lose any employment benefit, or any other benefit,
inheritance, or bequest under the 1953 Trust as a result of meeting with or providing information to law enforcement; (ii)
the Co-Executors have not made any distributions to Ghislaine Maxwell and will notify the United States Attorney's Office
for the Southern District of New York in advance of any disbursement to her during the pendency of the criminal
proceeding against her in the Southern District of New York; and (iii) the Co-Executors are not prepared at this time to
waive any applicable privileges, including the attorney-client privilege, with respect to any materials obtained or seized by
the Government.
Please let us know if you have additional questions.
Best regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor New York, NY 10004-1482
Office
Cell
I Fax +1 (212) 299-6460
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
EFTA00020668

=== Page 2 ===
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Sunday, July 26, 2020 2:51 PM
To: Weinstein, Marc A.
>; ; Andrew Tomback
Cc:
is
Subject: RE: SDNY investigation
CAUTION: This email was sent by someone outside of the Firm.
Andy, Marc,
Following up on our recent discussions, please see the attached letter from our Office.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00020669


c1: EFTA00021028
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c3: VOL00008
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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell Bail Application Exhibits
Date: Wed, 09 Dec 2020 15:14:33 +0000
Attachments: 2020-12-08_defense_renewed_motion_for_bail_(2of2),_Redacted_Versions.zip
H
Please find attached a zip folder containing the second and final part of the exhibits pertaining to Maxwell's renewed bail
application. Thank you, and please let me know if you encounter any issues.
All the best,
From
(USANYS) [Contractor]
Sent: Wednesday, December 9, 2020 9:54 AM
To
Cc:
Subject: Maxwell Bail Application Exhibits
Hi
I hope you're both well! Please find attached a zip folder containing the exhibits pertaining to Maxwell's renewed bail
application. Thank you, and please let me know if you have any questions or encounter any issues.
Take care,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00021028


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c0:
=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 22 Oct 2021 16:25:36 +0000
Hi Jeff,
Hope you're doing well. Are you available for a call today or Monday to follow up on our conversation about a records
custodian testifying at trial?
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, May 14, 2021 10:50 AM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
I just reached out to Interlochen and they do not have a color version.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, May 14, 2021 at 10:38 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
Best,
EFTA00023182

=== Page 2 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Attached is what went in the mail today.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, II
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
Thanks,
Jeff
EFTA00023183

=== Page 3 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, I'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00023184

=== Page 4 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
>;
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00023185

=== Page 5 ===
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00023186

=== Page 6 ===
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00023187

=== Page 7 ===
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
EFTA00023188

=== Page 8 ===
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
EFTA00023189

=== Page 9 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00023190

=== Page 10 ===
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
EFTA00023191

=== Page 11 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
EFTA00023192

=== Page 12 ===
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
EFTA00023193

=== Page 13 ===
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00023194


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=== Page 1 ===
From:
To:
Subject: FW: Corruption and Ghislaine
Date: Mon, 06 Jul 2020 18:03:12 +0000
Attachments: EpsteinO'ConnellMaxwell.pdf; BILL_O'CONNELLChildRapeVictim.pdf
I think this is a repeat?
Pls handle.
From: Elle K
Sent: Monday, July 6, 2020 12:41 PM
To:
Subject: Corruption and Ghislaine
Hi,
My name is Lisa Kenney and I reside in NH. I have been reporting a group of wealthy MA
real estate developers, nightclub and restaurant owners, along with rogue police who cater
to them, donate for them, and seemingly offer private police services to them.
One of the MA troopers is the brother of the nightclub owners and he's close to pedophile
wealthy developer Wm. O'Connell. (arrested for statutory rape and cocaine trafficking)
| have come across new information which leads me to believe the above group is tied to
Epstein, and even Ghislaine, but definitely the million dollar homes where she lived and the
LLC's connected to them.
| have attached these documents on both a Google doc and PDF file for your viewing.
I know this group, with the exception of the pedophile and nightclub owners, because I was
married to one | divorced over twenty years ago, I dated another, and socialized with them.
| have been compiling their corruption for over ten years and have received enormous
amounts of abuse and crimes committed against me for doing so, and LE hasn't done one
thing to stop them.
But, I'm still here sending my reports on them, and they're still issuing threats. They
frequently tell me they will continue the abuse and destruction to my property as long as I
keep reporting them and their ties to nightclub owners, political policing, O'Connell, and
obvious money laundering.
This pedophile's victim was killed in a fiery crash one week before his trial was to begin, so
he got off those charges. But the similarities between both he and Epstein are astounding,
and I'm sure they knew him.
Google docs
EFTA00021170

=== Page 2 ===
Epstein & Ghislaine
Another wealthy predator who appears tied to Epstein and Ghislaine,
Wm OConnell doc.
See attached.
Thank you,
Lisa Kenney
EFTA00021171


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Defective Document CURED"
Date: Tue, 26 Jan 2021 18:18:36 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 01/26/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Docket Text:
CURED DEFECTIVE ACKNOWLEDGMENT AND NOTICE OF APPEARANCE [13], on behalf of Appellant
Ghislaine Maxwell, FILED.[3021129] [21-58]
Notice will be electronically mailed to:
Mr. Christian Romeyn Everdell, Assistant U.S. Attorney: ceverdell@cohengresser.com,
managingclerksoffice@cohengresser.com
Assistant U.S. Attorney:
Notice will be stored in the notice cart for:
Quality Control 1
EFTA00020971


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Second Daubert Motion
Date: Mon, 15 Nov 2021 20:38:09 +0000
Attachments: Motion_to_preclude_Hall_et_al_v3_JME.docx
Thanks guys.
S comments are in the attached. I reviewed in hard copy and therefore just gave
the few nits I
had rather than adding them on top.
From:
Sent: Sunday, November 14, 2021 11:41 PM
To:
Cc:
Subject: Second Daubert Motion
Hi Chiefs,
I hope you had a nice weekend! Attached is our second Daubert motion for your review. It is due tomorrow.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023416


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
November 20, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
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.
EFTA00023360

=== 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,
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00023361


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=== Page 1 ===
From:
"
,
(USANYS)"
To:
(USANYS)"
Subject: RE: Filed version of Epstein papers
Date: Wed, 17 Jul 2019 13:45:19 +0000
Yes, these are fine; thanks
From:
(USANYS)
Sent: Wednesday, July 17, 2019 9:43 AM
To:
(USANYS)
Subject: RE: Filed version of Epstein papers
Are you referring to the papers filed yesterday? If so, they are attached. These are the publicly filed versions -if you want
our unredacted version of the submission, just let me know.
From:
(USANYS)
Sent: Wednesday, July 17, 2019 9:37 AM
To:
(USANYS)
Subject: Filed version of Epstein papers
Would you pls send me? Sorry if this is request for resend, but if you sent, I can't find it.
Thanks.
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
Tel.:
EFTA00022520


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
Date: Fri, 26 Jul 2019 02:20:39 +0000
Thanks very much. Would 10:00 a.m. tomorrow your time (noon our time) work? If so, we can call you then at
or if not, we could also do 2:00 p.m. your time.
thanks,
From:
Sent: Thursday, July 25, 2019 22:13
To:
Cc:
is
Subject: Re: Briefing in Florida regarding whether the Florida NPA extends to New York
Happy to chat tomorrow. Name your time that's convenient for you.
- sent from my iPhone - please excuse brevity and errors.
On Jul 25, 2019, at 8:07 PM,
wrote:
Thank you for sending us these materials, we appreciate being able to stay up to date, and we'll continue to keep an eye
on the docket for submissions that may be relevant for our investigation.
Separately, might you be available for a quick call sometime tomorrow (Friday) or next week? No rush or emergency,
but we wanted to talk with you about a question in connection with your expertise on the CVRA generally. At your
convenience.
thanks,
From:
Sent: Thursday, July 25, 2019 13:01
To:
Cc:
is
)
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
Hi
I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See attached.
You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies in the case
that relate solely to Florida crimes and Florida victims because the NPA only covers Florida.
EFTA00021392

=== Page 2 ===
We filed our reply brief on remedies on Tuesday - and that should have brought all briefing on remedies for the CVRA
violation to a close. But yesterday Epstein's lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In
point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things, the
scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It appears
that Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.
I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to
New York or other jurisdictions - and that is the point we are making to Judge Marra.
for Jane Doe 1 and 2
(phone)
(fax)
You can access my publications on
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to
the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00021393


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=== Page 1 ===
Vasaparken
Atlasomradet
Humlegarden
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OSTERMALM
-
Kungsgatan
521
NORRMALM
KUNGSHOLMEN
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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456-1 approved by
, now awaiting further
approval
Date: Tue, 24 Sep 2019 20:19:48 +0000
Importance: Normal
Dear
Travel authorization 10643456-1 has been approved by
, now awaiting further approval.
Trip ID: 10643456-1
Traveler name:
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-09-17 - 2019-09-20
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.
EFTA00023238


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=== Page 1 ===
From:
To:
Cc:
Subject: Discovery questions
Date: Tue, 18 Aug 2020 08:33:11 +0000
Attachments: Miami_Case_Docs.pdf
Hi
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery Paul dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
Mandy mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would
you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard
copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned,
including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or
partially nude images. For nude or partially nude images, please provide us with a log detailing how many such
images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images.
For nude or partially nude images, please provide us with a log detailing how many such images were located,
where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
EFTA00022197

=== Page 2 ===
New York, NY 10007
EFTA00022198


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=== Page 1 ===
From:
To:
<
Cc:
>
Subject: Re: MCC Visit Thursday
Date: Tue, 13 Aug 2019 19:37:41 +0000
Hi
It should not be a problem. Does 10 am work for Mr. Berman and the rest of his staff?
Thank you
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
> 8/13/2019 2:05 PM >>>
The list of visitors from our office is below:
As discussed, we would like to see the 2nd floor pscyh observation and suicide watch area; the 9th floor SHU, and Epstein's
cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would escort us,
and we will not speak to any of the guards present given the ongoing investigations. Please give me a call with any
questions, and let us know what time and where we should go, and if it would be easier for us to enter via the 3rd floor
bridge.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00022630


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=== Page 1 ===
BOIES
BSF
MATTHEW L. SCHWARTZ
SCHILLER
Tel.:
FLEXNER
E-mail:
October 15, 2019
BY ELECTRONIC MAIL
Assistant United States Attorney
One Saint Andrew's Plaza
New York, New York 10001
Re:
Hyperion Air, LLC
Dear AUSA Moe:
I am writing to briefly follow up on our conversation this afternoon. As I told you, I
represent a client who has been in negotiations to purchase a Keystone (Sikorsky) model S-76C
helicopter from a U.S. Virgin Islands entity called Hyperion Air, LLC. The agreed-upon purchase
price for the aircraft is $3.5 million, with a $100,000 deposit that my client has already paid into
escrow. The parties are currently negotiating a final purchase agreement, and the seller — who as I
mentioned is being represented by Darren K. Indyke - is pushing for a November 15, 2019 closing
for the transaction.
We have recently come to understand that Hyperion Air, LLC is an entity associated with
Jeffrey Epstein. We therefore wanted to advise your Office of this transaction before it is finalized.
Although my client has no reason to believe that the aircraft may be subject to forfeiture - it was
not identified in the forfeiture language of the charging instruments against Epstein, it was not
acquired by Hyperion Air until long after the charged conduct, and we have no reason to believe
that it was purchased with criminally-derived funds or is otherwise potentially subject to forfeiture
- we of course wanted to give the Office the opportunity to take any action that it may deem
appropriate, including blocking the transaction or ensuring that the proceeds are deposited into
escrow.
As we discussed, we look forward to hearing back from the Office. As I mentioned when
we spoke, in the absence of guidance from the Office, it is my client's intention to proceed with the
transaction. If we do not hear back from you before then, I will check back in before my client
signs the purchase agreement.
Respectfully,
/s/ Matthew L. Schwartz
Matthew L. Schwartz
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards, New York, NY 10001 I (t) 212.446.2300 I (f) 212.446.2350 I www.bsfllp.com
EFTA00021344


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=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
(USANYS)"
)"
i
)"
Christian Everdell
>, Laura Menninger
Jeff Pagliuca
,
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330
Date: Sat, 13 Nov 2021 05:20:59 +0000
Attachments: 2021-11-12_GM_letter_re_GX_52_Redacted.pdf; 2021-11-
12_GM_letter_re_GX_52.proposed_redactions.pdf,GX-52-G.pdf
Chambers,
The Government respectfully submits the attached letter, both unredacted and with proposed redactions, along with the
exhibit referenced in the letter, which is respectfully requested to be filed under seal. The Government has filed a version
on ECF that implements the proposed redactions.
Thank you.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00023411


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 11, 2019
VIA EMAIL
Deutsche Bank AG, New York Branch /
Deutsche Bank Securities Inc.
Attn: Andrew Stemmer
60 Wall Street
New York, NY 10005
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Please note that this is an expedited request for a time-sensitive matter.
Thank you for your cooperation in this matter.
Very truly yours,
By:
EFTA00022527

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Deutsche Bank AG, New York Branch /
Deutsche Bank Securities Inc.
Attn: Andrew Stemmer
60 Wall Street
New York, NY 10005
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
July 25, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b)
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Assistant U.S. Attorney
at: U.S. Attorney's
Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: 212-
637-2415, or via email at
; and (2) accompanied by an executed copy
of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC
FORMAT IF POSSIBLE.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 11, 2019
UNITED STATES DISTRICT COURT
FOR
THE
RICT
YORK
EFTA00022528

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Deutsche Bank AG, New York Branch / Deutsche Bank Securities Inc,
dated July 11, 2019)
Please provide the following information for open or closed individual, joint, or
commercial accounts, or related or affiliated accounts, associated with the entities, individuals,
social security numbers, and/or account numbers identified below, for the period January 1, 2010,
to the present:
Individual:
Jeffrey Epstein
Date of Birth: 01/20/53
SSN: 090-44-3348
NOTE: When producing results for multiple accounts in electronic form, please produce
records for each account on a SEPARATE disk and using "Image Onsite".
Please include in your response related or affiliated accounts identified by name, address, Social
Security Number(s), Employer Identification Number(s), driver's license number(s), financial
account number(s), corporate/d.b.a records, Tax Identification Number(s), internal investigative
findings or other means, for the period January 1, 2010, to the present.
Any and all records in your care, custody, possession or control, including but not limited to:
1. Records relating to "Know Your Customer" filings, submissions, forms, requests,
supplements, and questions and answers;
2. Records relating to the opening and/or closing of accounts, including account
applications, signature cards, proof of identification, corporate resolutions, and related
records (to be included even if dated outside the above-specified time period);
3. All account monthly or other periodic statements and/or transcripts;
4. Signature cards, and any other documents reflecting the identities of individuals
authorized to conduct transactions in, or have access to, the accounts;
5. Records relating to or reflecting the names, addresses, social security numbers, and /or
employer identification numbers of all account holders;
6. Loan and/or lines of credit applications and files;
7. All account deposit and withdrawal items;
8. Deposit records including deposit slips, items deposited, and all documents and records
or information indicating sources of deposited funds;
9. Withdrawal and deposit records including withdrawal and deposit applications, drafts,
wire transfers, and all other documents showing any record or information relating to the
destination or disposition of withdrawn or wired funds;
3
EFTA00022529

=== Page 4 ===
10. Cancelled checks (both front and back);
11. Debit and credit memoranda and related documents;
12. Records of and relating to all cashier's checks, bank checks, teller checks, certified
checks, money orders, traveler's checks, and/or other official checks issued to, or on
behalf of, any account holder;
13. Credit card accounts;
14. Loan files, including all applications and supporting documentation, to include financial
statements, credit reports, and appraisals, loan approval records, promissory notes,
mortgages, security agreements, and loan repayment records, to include any records or
information relating to payment sources;
15. Safe deposit records, including applications, signature cards, and any records relating to
access;
16. Currency transactions reports (IRS Forms 4789) and other required reports made to any
regulatory or law enforcement authority;
17. Account opening documents to include photocopies if ID, SSN card etc.;
18. Any correspondence to, from, or relating to accounts, account-holders, or other
individuals associated with accounts, including any recorded customer service telephone
calls, and including correspondence with any regulatory or law enforcement authority;
19. Memoranda, notes or other records of telephone conversations associated with accounts
or individuals associated with accounts (including conversations with any regulatory or
law enforcement authority);
20. Internal memoranda and reports;
21. Computer records / logs of any communication or attempted communication with the
customer;
22. Customer service call logs;
23. Trust accounts;
24. Any email addresses associated with the accounts/account holders;
25. All surveillance video and/or photographs of transactions;
26. Any and all corporate resolutions, certifications of incorporation, business certificates
and/or partnership agreements; and
27. Any and all correspondence, electronic or otherwise, including memoranda, emails and
text messages, that reference or concern items (1) through (26), above, and/or any
financial interests involving the individuals and/or entities identified in Section A.
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Assistant U.S. Attorney
at: U.S. Attorney's Office,
executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN
ELECTRONIC FORMAT IF POSSIBLE.
4
EFTA00022530

=== Page 5 ===
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
5
EFTA00022531

=== Page 6 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated July 11, 2019, and signed by Assistant
United States Attorney
,
requesting specified records of the business named below.
Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the
records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
EFTA00022532


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=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: SDNY PRESS GUIDANCE | U.S. V. GHISLAINE MAXWELL, TUESDAY,
NOVEMBER 23, 2021
Date: Tue, 23 Nov 2021 14:34:13 +0000
Attachments: 2021.11.01_Pseudonym_ruling_from_Transcript.pdf;
2021.11.10_Pseudonym_logistics_order.pdf;2021.11.18_Maxwell_-
_Sketch_Artist_Order.pdf
Inline-Images: image001.png
Just FYSA.
Sent from my iPhone
Begin forwarded message:
From:
Date: November 23, 2021 at 8:24:16 AM EST
Cc:
Subject: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, TUESDAY, NOVEMBER 23,
2021
In order meet the demand for the high volume of media requests we are already receiving, the following
guidance is being provided in advance of the trial to ensure efficient communications. Please take careful note.
PRESS GUIDANCE
Tuesday, November 23, 2021
*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses
will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion
[attached] requesting that they be able to do so, because the victim witnesses are expected to describe alleged
sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of
which they have been victims. I believe most, if not all, news media outlets have a policy against identifying
sex crime victims without their consent, and urge you to abide by that policy with our witnesses and respect
their privacy.
9:30 a.m. - Final pretrial conference U.S. V. Ghislaine Maxwell - the defendant is charged in connection to
conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity - - before Judge
Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the
Thurgood Marshall U.S. Courthouse]).
EFTA00023367

=== Page 2 ===
EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are
unable to access this link to the file share (USAFx), you must establish an account to access the files. To
establish an account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to
Wednesday, November 29, 2021.
Please also note that all case filings in U.S. V. Maxwell are available in the Court's electronic filing system; we
encourage media representatives to establish a free PACER account, if they have not done so already.
Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District
Executive's Office.
Periodic updates to follow.
Follow us on Facebook I Follow us on Twitter | SDNY website | YouTube
*** FOR PLANNING PURPOSES ONLY ***
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS
OFFICE AT (212) 637-2600.
UNITED QUI PRO DOMINA JUSTITIA OF DEPARTMENT JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
EFTA00023368


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=== Page 1 ===
From:
To:
Subject: FW: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
Date: Wed, 29 Jul 2020 18:35:25 +0000
Attachments: 2020-07-29_[01078-].zip
Inline-Images: image001.jpg
I wanted to alert you that Maxwell's counsel just filed the attached public filing in the
V. Maxwell case.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com]
Sent: Wednesday, July 29 2020 2:07
To:
Subject: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
V. Maxwell
Docket entry number: 1078
LETTER addressed to Judge Loretta A. Preska from Ty Gee dated July 29, 2020 re:
Reconsideration of the Courts July 23 Ruling. Document filed by Ghislaine Maxwell.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E). (Gee, Ty) (Entered: 07/29/2020)
Date entered: 2020-07-29
VIEW CASE
https://app.pacerpro.com/cases/1833757
EFTA00021840

=== Page 2 ===
Sent from PacerPro, the fastest and most insightful way to access federal court records.
Questions? sales@pacerpro.com or (415) 890-4958
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
EFTA00021841


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=== Page 1 ===
From: "Lenghi, Mola"
Subject: Epstein question
Date: Fri, 26 Jul 2019 14:09:18 +0000
Inline-Images: Outlook-w335ivp3.png
Good morning,
Mola Lenghi with CBS News here. Hoping to confirm a report we're seeing out there.
Not sure if you can.
"Federal prosecutors have subpoenaed Jeffrey Epstein's longtime person pilots as investigators seek to question
the financier's employees in the wake of his indictment on sex-trafficking charges."
Confirmation?
Thanks for considering.
https://www.wsj.com/articles/jeffrey-epsteins-pilots-are-subpoenaed-in-sex-trafficking-investigation-
11564142402
CBS NEWS
Mola Lenghi
EFTA00021395


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007
January 6, 2020
By Electronic Mail and U.S. Mail
Roberta A. Kaplan
Kaplan Hecker & Fink LLP
New York, NY 10118
Re:
Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan:
I am the Assistant U.S. Attorney ("AUSA") who will be handling the request you
discussed with AUSA
for certain information relating to Jeffrey Epstein. Because
your request seeks information from Department of Justice (the "Department") employees
acquired as part of their performance of their official duties, your request is governed by certain
Department regulations-commonly referred to as Touhy regulations-which, inter alia, prohibit
any Department employee from disclosing such information "without prior approval of the
proper Department official in accordance with §§ 16.24 and 16.25 of this part." 28 C.F.R. §
16.22(a); see also United States ex rel. Touhy V. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21
et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for
the Southern District of New York. The Touhy regulations provide a set of procedures for the
United States Attorney to follow when considering such requests. See 28 C.F.R. §§ 16.22(b),
16.24.
A party seeking to obtain records or employee testimony from the Department must first
submit a written demand. See 28 C.F.R. § 16.22. To assist the United States Attorney in
evaluating your request, we ask that this demand provide a detailed statement of the information
sought; the litigation for which you seek this information; the pertinence of the information
sought to your litigation; and the availability (or absence) of means in that litigation, including
discovery, to obtain the information in question. See id. § 16.22(d).
The U.S. Attorney will reach a determination regarding your request in light of the
considerations codified at 28 C.F.R. §§ 16.24, 16.25, and 16.26. Such considerations include,
inter alia, "[w]hether such disclosure is appropriate under the rules of procedure governing the
case or matter in which the demand arose," 28 C.F.R. $ 16.26(a)(1), and "[w]hether disclosure is
appropriate under the relevant substantive law concerning privilege," including law enforcement
privilege. 28 C.F.R. § 16.26(a)(2). Disclosure will not be made when, inter alia, "[d]isclosure
would violate a statute or a rule of procedure, such as the grand jury secrecy rule," 28 U.S.C.
$ 16.26(b)(1), "[d]isclosure would reveal a confidential source or informant," 28 U.S.C. §
16.26(b)(4), or "[d]isclosure would reveal investigative records compiled for law enforcement
purposes, and would interfere with enforcement proceedings or disclose investigative
techniques," 28 U.S.C. $ 16.26(b)(5). Applying these considerations, the Department will make
appropriate disclosures when warranted. See 28 C.F.R. § 16.26(c).
EFTA00022146

=== Page 2 ===
Page 2
My understanding is that you may intend to make a formal written request pursuant to the
above-described regulations. If you choose to submit a written request, please send it directly to
me. We will act upon an application made pursuant to the Department's regulations.
Please contact me once you have had a chance to review this letter if you would like to
discuss the issues herein further.
Sincerely,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By:
Assistant United States Attorney
Telephone:
Facsimile:
E-mail:
EFTA00022147


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=== Page 1 ===
From:
)"
To: Christian Everdell
)"
Cc: "Mark S. Cohen"
, Jeff Pagliuca
'Laura Menninger'
Subject: RE: Protective Order
Date: Sat, 25 Jul 2020 20:13:13 +0000
Attachments: 2020-07-25,_GM,_protective_order_clean_version.docx
Inline-Images: image001.png; image002.jpg
Chris,
Following up on our discussion last night, attached please find a revised draft protective order. As we discussed, although
this does not represent a version that has been formally approved internally at our Office, it is an effort to include the
updates and edits we talked through yesterday. I believe this should represent what we addressed, but I also realize that
we've revised some aspects that you mentioned you'd need to further consider, and there is some new proposed
language in areas you suggested we clarify, so I expect it may be useful to chat again once you've reviewed. All that said,
we wanted to get you the revised version quickly, and I'm happy to discuss again, including anytime this weekend if that's
helpful, to go through any outstanding issues.
thanks,
From: Christian Everdell
Sent: Wednesday, July 22, 2020 20:13
To:
is
is
Cc: Mark S. Cohen
>; Jeff Pagliuca
>; ; 'Laura Menninger'
Subject: Protective Order
-
Attached is a revised draft of the defense's proposed Protective Order (including a redline against the government's
original draft and a clean version). We did our best to incorporate the points we discussed on our last call on Monday, July
20 and to find points of common ground and agreement. Please let us know by 5pm tomorrow whether the attached
draft is acceptable to the Government.
Regards,
Chris
Christian Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
EFTA00021918

=== Page 2 ===
view bio
www.cohengresser.com
New York
Seoul
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00021919


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=== Page 1 ===
From:
)"
To: John Reynolds
Subject: RE: SDNY investigation
Date: Fri, 25 Sep 2020 15:33:22 +0000
Hi John,
I just called your office and it looks like you're on another call. Please feel free to call my cell
(
whenever
you have a moment.
Thanks,
From: John Reynolds
Sent: Friday, September 25, 2020 11:14 AM
To:
Subject: RE: SDNY investigation
Ms.
I spoke to Mr.
Please give me a call when you have a moment. Thank you.
Kind regards,
John H. Reynolds, Esq.
Reynolds & Reynolds, P.L.
West Palm Beach, FL 33401
office
fax
Privileged and Confidential
E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication
originates from the law firm of Reynolds & Reynolds, P.L. and is protected under the Electronic Communication Privacy
Act, 18 U.S.C. S2510-2521. The information contained in this e-mail message is intended for the use of the individual or
entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from
disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent
responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure
or dissemination of this communication may be subject to legal restriction or sanction. Personal messages express views
solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify
the sender immediately by e-mail or by telephone at
From:
Sent: Friday, September 25, 2020 10:38 AM
To: John Reynolds
Subject: RE: SDNY investigation
This is the article I mentioned:
EFTA00023128

=== Page 2 ===
https://nypost.com/2020/09/23/ex-staffer-says-ghislaine-maxwell-hated-jeffreyepstein-but-couldnt-leave-hm/
From: John Reynolds
Sent: Friday, September 25, 2020 10:22 AM
To:
Cc:
>;
(USANYS)
Subject: RE: SDNY investigation
Yes. I am available now if you have a moment. If so, please call me.
Kind regards,
John H. Reynolds, Esq.
Reynolds & Reynolds, P.L.
West Palm Beach, FL 33401
office
fax
Privileged and Confidential
E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication
originates from the law firm of Reynolds & Reynolds, P.L. and is protected under the Electronic Communication Privacy
Act, 18 U.S.C. S2510-2521. The information contained in this e-mail message is intended for the use of the individual or
entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from
disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent
responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure
or dissemination of this communication may be subject to legal restriction or sanction. Personal messages express views
solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify
the sender immediately by e-mail or by telephone at
From:
Sent: Friday, September 25, 2020 10:18 AM
To: John Reynolds
Cc:
is
(USANYS)
Subject: RE: SDNY investigation
Hi John,
I hope you're doing well. Are you available for a brief call today or Monday regarding Mr.
?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023129

=== Page 3 ===
From: John Reynolds
Sent: Friday, July 10, 2020 5:40 PM
To:
Cc:
is
Subject: RE: SDNY investigation
It was nice to speak with you as well. Don't hesitate to call me if you need anything. I hope you all have a terrific
weekend.
Kind regards,
John H. Reynolds, Esq.
Reynolds & Reynolds, P.L.
West Palm Beach, FL 33401
office
fax
Privileged and Confidential
E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication
originates from the law firm of Reynolds & Reynolds, P.L. and is protected under the Electronic Communication Privacy
Act, 18 U.S.C. S2510-2521. The information contained in this e-mail message is intended for the use of the individual or
entity to which it is addressed and may contain information that is proprietary, privileged, confidential, and exempt from
disclosure under applicable laws. If the reader of this message is not the intended recipient, or the employee or agent
responsible for delivery to the intended recipient, you are hereby notified that any use, printing, reproduction, disclosure
or dissemination of this communication may be subject to legal restriction or sanction. Personal messages express views
solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify
the sender immediately by e-mail or by telephone at
From:
Sent: Friday, July 10, 2020 5:38 PM
To: John Reynolds
Cc:
is
Subject: RE: SDNY investigation
John,
Thanks again for chatting earlier today regarding your representation of Mr.
As I mentioned on the phone, we
appreciate his cooperation with our investigation thus far, and we do expect we likely would call him as a witness at a
Maxwell trial. In the interim, please do not hesitate to be in touch with us if any questions or issues arise, and as you
mentioned, it would be helpful if you could please let us know if he receives any subpoenas or other legal process or
relevant requests.
As promised, we also want you to have contact info for our full team - my colleagues
and
are copied
here, and we're all reachable any time at these email addresses or at the following phone numbers:
(office)
(cell)
(office)
EFTA00023130

=== Page 4 ===
(cell)
(office)
(cell)
thanks again,
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Subject: RE: CORRECTION: vendor processes for Epstein case
Date: Mon, 19 Aug 2019 18:34:10 +0000
Thanks very much, and confirmed that we received the drive last week. Thanks again.
From:
)
Sent: Monday, August 19, 2019 14:29
To:
)
Subject: FW: CORRECTION: vendor processes for Epstein case
FYI.
From:
Sent: Monday, August 19, 2019 2:21 PM
To:
Subject: Re: CORRECTION: vendor processes for Epstein case
,
Please confirm the AUSA received the hard drive with the audio cassette transfers on Friday.
Also, please have your staff back up the drive and archive as well.
The video transfers will be ready tomorrow.
Below, you will find the breakdown of fees.
I will make arrangements with
to pick up the tapes.
As always, thank you.
Sincerely,
Fees:
Audio Cassettes (49 tapes total)
(36) 90 minute length. 36 X 1.5 (hr) = 54 hours
(13) 60 minute length 13 X 60 (hr) = 13 hours
TOTAL 67 hours
67 X $60.00 $4020.00
Video Cassettes (13 tapes total)
(6) T120 length 6X4 (hr) = 24 hours
(7) T160 length 7X6 (hr) = 42 hours
TOTAL 66 hours
66 X $105.00 $6930.00
Editing
Audio 3 X $175 = $ 525.00
Video. 2.5 X $175 = $ 437.50
Archiving. 2 X $175 = $ 350.00
Hard Drives
Recycled 2 X $0.00 = $ 0.00
Total Due $12,262.50
On Thu, Aug 15, 2019 at 2:18 PM
)
wrote:
Yes. Send what is completed at this time.
Thanks.
From:
Sent: Thursday, August 15, 2019 1:44 PM
To:
Subject: Re: CORRECTION: vendor processes for Epstein case
,
The speed is "long play" meaning 4-hours verses 2-hours (NOT 6-hrs).
EFTA00021759

=== Page 2 ===
This is a bit faster, better.
On Thu, Aug 15, 2019 at 1:38 PM
wrote:
As mentioned, the audio transfer is complete. Would you like those files tomorrow, as separate from the
video transfers? Or all at once (both audio/video) next week?
As a follow up to the video lengths, most of the VHS tapes were recorded at slow speed or "extended play".
This means the length of each tape is 6-hrs (verses 2-hours at normal speed).
We spoke about preserving the entire tape. Just letting you know in advance. Of course, the estimate will
reflect these extended times.
On Thu, Aug 8, 2019 at 8:17 PM
)
wrote:
Yes. I am in at 8:10.
Sent from my iPad
On Aug 8, 2019, at 8:16 PM,
wrote:
Are you available to talk tomorrow morning sometime?
A few details I want to speak with you about.
Thanks.
On Fri, Jul 26, 2019 at 12:05 PM
wrote:
Thanks
On Fri, Jul 26, 2019 at 11:45 AM
)
wrote:
What address?
From:
Sent: Friday, July 26, 2019 8:28 AM
To:
Subject: Re: FW: RE: vendor processes for Epstein case
Good morning
Yes, I can definitely help.
What is the time frame for this?
On Fri, Jul 26, 2019 at 8:11 AM
)
wrote:
In an obvious high profile case, we have VHS tapes and cassettes. Are you in this line of work?
The below is from the AUSA
Video and Audio:
For the video and audio records, those materials include approximately 22 VHS tapes and
approximately 49 cassette tapes, each of which needs to be converted, labeled, and indexed, and
we'll need two copies of each resulting digital file (again, one for us and one for FBI). Those are
also currently in our possession, in my office.
President
LegalAudioVideo
www.legalaudiovideo.com
EFTA00021760

=== Page 3 ===
Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is
privileged and confidential information intended only for the use of the individual(s) named above and should not be
construed as legal advice. If the reader of this message is not the intended recipient, you are hereby notified that any
dissemination, distribution or copy of this communication is strictly prohibited. If you have received this
communication in error, please contact the sender by reply e-mail and destroy all copies of the original message.
President
LegalAudioVideo
www.legalaudiovideo.com
Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is privileged
and confidential information intended only for the use of the individual(s) named above and should not be construed as
legal advice. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please
contact the sender by reply e-mail and destroy all copies of the original message.
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LegalAudioVideo
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Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is privileged
and confidential information intended only for the use of the individual(s) named above and should not be construed as legal
advice. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution
or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the
sender by reply e-mail and destroy all copies of the original message.
President
LegalAudioVideo
www.legalaudiovideo.com
Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is privileged and
confidential information intended only for the use of the individual(s) named above and should not be construed as legal advice.
If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of
this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply e-
mail and destroy all copies of the original message.
President
LegalAudioVideo
www.legalaudiovideo.com
Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is privileged and
confidential information intended only for the use of the individual(s) named above and should not be construed as legal advice. If
the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this
communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply e-mail and
destroy all copies of the original message.
President
LegalAudioVideo
www.legalaudiovideo.com
Attention: Legal Audio Video cannot provide legal advice. The information contained in this e-mail message is privileged and
confidential information intended only for the use of the individual(s) named above and should not be construed as legal advice. If the
EFTA00021761

=== Page 4 ===
reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this
communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply e-mail and
destroy all copies of the original message.
EFTA00021762


c1: EFTA00020578
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020578.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Al
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
05192011
Dec Code Doc Code Dec Code Doc Code Account Numbers
942
Account Numbers
GOVERNMENT
EXHIBIT
506
5220 Cr. 330 (AJN)
Confidential Treatment Requested by
JPM-SDNY-00002407
JPMorgan Chase
EFTA00020578

=== Page 2 ===
134109791 AJ 00 000000
1301
19953-524-00722-0
8389
200019 R07067
Department of the Treasury
Date of this notice:
MAY 22, 2000
Internal Revenue Service
Taxpayer Identifying Number
13-4109791
HOLTSVILLE NY 00501
Form:
Tax Period:
For assistance you may
call us at:
1-800-829-1040
Or you may write to US at
the address shown at the
left. If you write, be
AIR GHISLAINE INC
sure to attach the bottom
457 MADISON AVE 4TH FLR
part of this notice.
NEW YORK NY 10022-6809570
NOTICE OF ACCEPTANCE AS AN S-CORPORATION
YOUR ELECTION TO BE TREATED AS AN S-CORPORATION WITR AN ACCOUNTING PERIOD OF
DECEMBER IS ACCEPTED. THE ELECTION IS EFFECTIVE BEOINNING JAN. 28, 2000, SUBJECT TO
VERIFICATION IF WE EXAMINE YOUR RETURN.
IF YOUR EFFECTIVE DATE IS NOT AS REQUESTED, IT WILL HAVE BEEN CHANGED FOR ONE OF
TWO REASONS. EITHER YOUR ELECTION WAS MADE AFTER THE 15TH DAY OF THE THIRD MONTH OF
THE TAX YEAR TO WHICH IT APPLIES, BUT BEFORE THE END OF THAT TAX YEAR, OR THE ELECTION
WHEN SUBMITTED WAS INCOMPLETE, AND REQUESTED INFORMATION WAS RECEIVED AFTER THE FILING
PERIOD. IN EITHER CASE, YOUR ELECTION IS INVALID FOR THE TAX YEAR REQUESTED AND HAS
THEREFORE, BEEN TREATED AS THOUGH IT WERE MADE FOR THE NEXT TAX YEAR.
PLEASE KEEP THIS NOTICE IN YOUR PERMANENT RECORDS AS VERIFICATION OF YOUR
ACCEPTANCE AS AN S-GORPORATION.
IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE OR THE ACTIONS WE HAVE TAKEN, PLEASE
WRITE TO US AT THE ADDRESS SHOWN ABOVE. IF YOU PREFER, YOU MAY CALL US AT THE IRS
TELEPHONE NUMBER LISTED IN YOUR LOCAL DIRECTORY. AN EMPLOYEE THERE MAY BE ABLE TO
HELP YOU: HOWEVER, THE OFFICE AT THE ADDRESS SHOWN ON THIS NOTICE IS MOST FAMILIAR
WITH YOUR CASE.
IF YOU WRITE TO US, PLEASE PROVIDE YOUR TELEPHONE NUMBER AND THE MOST CONVENIENT
TIME FOR US TO CALL SO WE CAN CONTACT YOU TO RESOLVE YOUR INQUIRY. PLEASE RETURN THE
BOTTOM PART OF THIS NOTICE TO HELP US IDENTIFY YOUR CASE.
THANK YOU FOR YOUR COOPERATION.
To make sure that IRS employees give courteous responses and correct information to taxpayers, a second IRS employee sometimes listens in on
telephone calls.
Overlay 5 Form 8489 (Rev. 8-9
Keep this part for your records
Return this part to us with your check or inquiry
Your telephone number
Best time to call
) -
134109791 AJ
00 000000
261
INTERNAL REVENUE SERVICE
HOLTSVILLE NY 00501
AIR GHISLAINE INC
2 pages
11/15/06
457 MADISON AVE 4TH FLR
NEW YORK NY 10022-6809570
150
Confidential Treatment Requested by
JPM-SDNY-00002408
JPMorgan Chase
EFTA00020579

=== Page 3 ===
x
DEPARTMENT OF THE TREASURY
DATE OF THIS NOTICE: 04-14-2000
INTERNAL REVENUE SERVICE
NUMBER OF THIS NOTICE: CP 575 A
HOLTSVILLE NY 00501
EMPLOYER IDENTIFICATION NUMBER: 13-4109791
FORM: SS-4
1925507677 B
FOR ASSISTANCE CALL US AT:
1-808-829-1040
AIR GHISLAINE INC
457 MADISON AVE 4TH FLR
NEW YORK NY 10022
OR WRITE TO THE ADDRESS
SHOWN AT THE TOP LEFT.
IF YOU WRITE, ATTACN THE
STUB OF THIS ROTICE.
WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER (EIN)
Thank you for your Form SS-4, Application for Employer Identification Number
(EIN). We assigned you EIN 13-4109791. This EIN will identify your business account,
tax returns, and documents, even if you have no employees. Please keep this notice in
your permanent records.
Use your complete name and EIN as shown above on all federal tax forms, payments,
and related correspondence. If you use any variation in your name or EIN, it may
cause . delay in processing, incerract information in your account, or ceuse you to be
eweigned sere than one EIN.
Bewed on the information shown on your Fore 55-4, you must file the fellowing
form(s) by the date we show.
Form 1120
02/15/2001
Your assigned tex clawsification is based en information obtained free your Form
SS-4. It is not a legal detarmination of your tax classification and is not binding
on the IRS. If you want a determination on your tax classification, you may seek a
private letter ruling from the IRS under the procedures set forth in Rev. Proc. 98-01,
1998-1 I.R.B. 7 (or the superceding revenue procedure for the year at issue).
If you need help in determining what your tex year is, you can get Publication
538, Accounting Periods and Methods, at your lecal IRS office.
If you have questions about the farme shown or the date they are due, you may
call us at 1-800-829-1040 or write to us at the address shown above.
If you're required to deposit for employment taxes (Forms 941, 943, 940, 945,
CT-1, or 1042), excise taxes (Form 720), or income texes (Form 1120), we will wend an
initial supply of Federal Tax Depssit (FTD) couson books within six weeke. You can use
the enclosed coupons if you need to make a deposit before you receive your supply.
Start your business off right - pay your taxes the easy way. Pay through the
Electronic Federal Tax Payment System (EFTPS). For information about EFTPS, call
1-800-829-3676 and request Publication 966, EFTPS Answere to the Most Ccauonly Asked
Questions.
Confidential Treatment Requested by
JPM-SDNY-00002409
JPMorgan Chase
EFTA00020580

=== Page 4 ===
The Morgan Account
Accounttype
Account number
/
/
Account ype
Account number
ONE BELOW)
Month
Date
NW
Social Security ne / Tax ID no. / Passport no.
Account title
BAC #
AN Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed
Print (Accountholdes/Signes, Trustee, Custodian, Director etc)
Time
the
Ghislaine MAXwell, President
...
X
Gaz If facimile signature. check box
Print (loint Accountholder/Signer, Trustee, Custodian, Director m)
Tde
If facsimile signature, check box
...
HARRY Beller, Secretary
HERE
X
Hay file
Print (other)
Title
# facsimile signature, check box
SIGN
HERE
X
Print (other)
Title
n facsimile signature. check box
SIER
HER:
X
IS this an existing account?
I
no
If yes, does this card replace al other cards against this account'
yes
20
Signing instructions (Please use back of card if necessary)
The Morgan Account
Account ype
Account number
/
/
Account ype
Account number
COMELE ...
Month
Date
year
Social Security no / In ID no Passport no
Account the
BAC #
All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed.
Print (Accountholder/Signer, Trustee, Custodian Director, etc)
Title
If facsimile signature, check box
Ghishire Maxwell, President
5158
HERE
X
Print Cloint Accountholder/Signer, Trustee, Custodian, Director, ex)
Title
R If facsimile signature, check box
SIGN
HARRY Beller, Secretary
WERE
X Hoy Kale
Print (other)
Title
If facsimile signature, check box
SIGN
HERE
X
Print (other)
Title
If facsimile signature, check box
SIGN
HERE
X
is this an existing account?
yes
no
⑈ yes, does the card replace all other canis agent the accure?
yes
no
Signing instructions (Please use back of card if necessary)
739474324
ipage
11/15/06 194
Confidential Treatment Requested by
JPM-SDNY-00002410
JPMorgan Chase
EFTA00020581

=== Page 5 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
I, Harry Bella
the Secretary (or day authorized officer) of Air titulare,
1x
(the "If Deganization") duly organized
under the laws of
herby catify that the following is me and complete copy of resolutions adopted by the
Hoard of Directors of the ligitation by united written consent or AT . meeting OR 18th day September
2006
at which a questum of the Hourd of Directors was procent and vocing and that these accolutions have not been resended or modified and are nos
in full force and effect.
A. Authorized signers
In this space. please list, by names or titles the persons authorized to sign of ICT pursuant resulutions indicated below (signers must be
identified in each resolution as passed) Alam each signet may act singly into the - below and the word "South" to without in.
which means that any Date signers must act points.
Ghishine MAXWELL, President
Singly
Print Name Title (if any) Title Onle
Manner of Signing
HARRY Bella, Secretary
singly
Print Name and Title (if any) THE Title Only
Manner of Square
Print Name and Title (if any) or Title Only
Manner of Stating
Print Name and Title (if any) or Title Only
Manner of Signing
Print Name and Title (if any) or Title Only
Manner of Signing
"A photo copy of a current Driver's License of Passport and social security number are required for each signer listed above.
Please check the line to the left of any one or more of the following resolutions which have been adopted If the line to the left of any
particular lettered subdivision is not checked. that resulution has not been adopted
B. Banking and custody
X1 RES M.VED. that the individuals stuntified drove are authorized cuter - and custudy accounts with IPMorgan have Honk,
NA or a Morgan Affiliate (individually on collectively. "Morgan") and my as or asigns designating Morgan as A depository of the funds
and currodian of the accurities of the Organization and to at on behif of the Organization in all respects regarding the Departation's banking
and custody accounts with Morgan as they is their discretion determine
C. Investment management
2. RESOLVED that the persons specified above are authorized in the name and on behalf of the Organization execute an investment
management agreement designating Mogga is the hymication's investment amount to Jeles DE mudify any 1941 allocation guiddine,
manding or other instruction and to at on behalf of the Organization to all spects fight line Organizations investment management
accounts with Morgan.
D. Brokerage
3. RES I.VED. that those persons identified above are authorized is the name and us behalf of the Reganization to execute 1 brukerage
agreement with JP Morgan Securities Inc and any - 11) any . to purchase magan " hereive and borne (un a secured IN
unscoured base) from, all (including sheet sales in . margin account) AND lead (ne included " universed busin) No. and enter into
of any kind with Morgan with resport to 115 and all recurres and financial intruments whatsoever in which Moggan may deal,
broker or act IS countriparty from time to time to unter into 201) derivative consultions with cont (1) the foregoing including LAST the counter
equity derivarives and structured transactions but are limited to options was collies caps and foon); to pledge any funds or
for the proposed of securing the Organization's diffigations with to the forgrag. to establish and operate *** 15 main
brokerage of other accounts IN commission with the foregring activities and manactions and to NT on behalf of the Organization in all respects
regarding the Organization's brokerage accounts
E. Credit
4. RESOLVED that those persons specified shows are authorized - the are and on to half of the Organization - benow from time
the - from Morgan - of for periods of DOC and upon terms as any (i) them - then discretion soun adverble: to execute notes SIE
other obligations to evidence borrowings, receiver - agreements with report to to discount with Morgan any bills - dates
ecceivable had by the Organization upon such terms or they may deem proper to spake in and Issue letters of credit and to execute applications.
agreements, must receipts and all other documents in consider therewith to records - deliver, n time discretion any indumery
acrectment or undertakings demod DECUSARY or advisible to CHITE out the purpose and state If of the foregring resolutions to plates any of the
assets of property of the Organization for the partick of securing any of the I income transacts - of Any transaction entered into In any other
entity or person. and to endorse Recantare and/or to issue appropoiate powers of afforted documents 113 assignments in furtherse durent.
Use Only
Title AIR GIR. UNR IN
SN
CAS
1 of 2
150
2 pages
11/15/04
Confidential Treatment Requested by
JPM-SDNY-00002411
JPMorgan Chase
EFTA00020582

=== Page 6 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
F. General
X5 RESOLVED. that these individuals ident fied - above. scring in the emer special theres, are authorized to dekyte the suthority
granted under the foregoing resolutions any other person by works appointment R Institud No Morgin and any such appointment shall own
in full force and effect until Morgan shall receive written BOXX to the contrary from de I
X 6. RESOLVED that any transaction of the type when by the procuders which has been taken are hereby in all respects
approved. confirmed and carified; and
7. RESOLVED that any resultation confied - Morgan by the Sucretary, if other duly appointed officer of the Organization shall formant in
full force and effect until Morgan shall receive cortification of * at request resolution - eding, supersoding DE revolving it.
X 8 RESOLVED. Any persons authorized to NT by the providing resolations may who the webs " provided by Morgan (the "Sitc") YM the
Internet 24 hours 1 day, seven days . week to ACT - the manager indicated en this . provided the functionality is available via the Siru
Transactions requiring fluids than one signature to complete will not be availa 4 va the Sin. Sin, exage by any Authorized Person is subject to the
website agreements and dischosistes available (91 the wibsite. or via hard empy M your request
G. Certification of incumbency
The following certificate of coumbency must be completed when the authorized - 15 admitional by title only
1 also certify this the following are officers the Information dected is appointed varil their SECURITY ADC elected or appointed and that you
shall be conticul to any upon their continued exembency and to (K) for the Registration until you have been furnished with . duly
certified notice " the Contract
Print Name
Tit
Date
Print Name
Title
Date
Print Name
Tite
Date
Print Name
Title
Date
I further certify that this Organization IS duly organized and existing and has the power and auchory to take the actions contemplated by the
foregoing resulutions
H. Signature
IN WITNESS OF WHICHT have at any hand as Secretary for other July of (ki) of due Organization -
Signature 180, Hang Day of hell September
this
2006
HARRY Beller, Secretary
09/18/06
Print Name an Title
Date
JPMorgan Use Only
Title
SPN
CAS
US150 05/06
20f2
150
Confidential Treatment Requested by
JPM-SDNY-00002412
JPMorgan Chase
EFTA00020583


c1: EFTA00023243
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023243.pdf
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=== Page 1 ===
1
8/19/2020
DOB
Brdd
= 54rs ago deposition -
ady for GM
FBI spoke w/ around time JE 1st went to
jail
live GA wl parents 1 1/2 yr
gf wl 2 kids
bio son lives wl his Mom
-work
born
live there South FL until around 25
went back $ forth from GA to FL
GED - got diploma HS
cooking Iserving /all around
diff restaurants since 18
EFTA00023243

=== Page 2 ===
2
2001
after met
engaged to other guy
friend hang out
10th grade
(passed away)
date
She stayed at
saw
pic on fridge " on is that
my house
"on mean
bro pick her
10th grade to 18 didnt see her
(
up - she go rehab
yr younger
rich guy PB - she work for
She there only 2 wks out of month
b/c She travel wl him (JE)
next day she be here if, want
say hi
paid for apt.
walk in w/ fiance
money coming from JE
she gave me nhug we clicked
w/in 2 w/ WKS She call off engagement
she kicked everyone out so / more in
picked up $ taken there (JE)
1 didnt meet him til latee
leave me w/ apt $ travel
) assume
Santa Fe, Ny, island
that going on
at time I told She massurse
) knew She work before at Mar a lago
1 think she met GM Mar- a- lago
EFTA00023244

=== Page 3 ===
3
couple months
going on trip
Jt want me drop her off - I met him
went inside kitchen
Jt say theyre going somewhere
I dont remember where
ask me if I knew other girls for
Jt to make Money for massages
"if 1 do, 1 dont have to go over as
much"
1 wanted see her more
recruited few girls
It try get those girls to bring
girls
girl we went school w/ @ Survivors
one of my
friends gf's - think her name
friend
guy wants to get Massages
JE paid me $ 200 cash
only him paid
EFTA00023245

=== Page 4 ===
4
ones I knew I drove
It paid me when I brought them
if he liked them he get Them a ride
& stay in touch w/ them
| met GM couple times
talk few minutes
she didnt call or ask me for anything
think
called me
would talk bout GM /sE
said She & GM go out to get girls
know girl
?
think that's the girl
left to
Jt ask/calling me about
pretty Married sure she told me She getting
1 think
took her to JE
EFTA00023246

=== Page 5 ===
5
this guy wants give Massages
sometimes It ask girls to do
More but dont have to if dont
want to
know
7
think that's the girl's boyfriend
familiar?
not sure
he was skinny white dude
C
- decent size breasts, crooked teeth
I think, not sure, brownish /reddish
hair
JE told me to make sure the girls
were 18
As far as ) knew they were my age
JE said make sure they're not fat
Asked about GM calling him
only met
(from prior int. Statement)
handfullimes of
GM may have called once or twice
but I didnt really deal wl her
EFTA00023247

=== Page 6 ===
6
JE giving
cash
phone bill
when I call her in
It paid for anything
1 was living at parents back then
said you know Jt pay FOR it
when I come back he take care of it
bill racked up - Jt didnt pay it
parents eventually paid it
It call my cell phone
after
left he calling me every
other day looking for her
ask me get girls wl her
Jt not contact me if
not around
call me when She wl w him &
ask for girls for When they get back
approach by Gm at Mar a lago
said GM $ her sexually active
w/ each other $ go out together
to get girls
EFTA00023248

=== Page 7 ===
7
book to fact check
got call from someone doing
get random calls from media
EFTA00023249


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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Copy of US V. Maxwell Juror Questionnaire Review JME 220-248.xlsx
Date: Sat, 06 Nov 2021 18:25:53 +0000
Attachments: Copy_of_US_v_Maxwell_Juror_Questionnaire_Review_IME_220-248.xlsx
Batch 2 for me.
EFTA00021964


c1: EFTA00022062
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022062.pdf
c6: pdf
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=== Page 1 ===
U.S. Department of Justice
Criminal Division
VAA:WHG:JEC:JTM
DOJ No. CRM-182-73090
Office of International Affairs
Washington, D.C. 20530
FROM:
The Central Authority of the United States
TO:
The Central Authority of the United Kingdom
SUBJECT:
Request for Assistance in the Matter of Material Witness PA
DATE:
April 3, 2020
The Central Authority of the United States of America ("U.S.") requests the assistance of
the Central Authority of the United Kingdom ("UK") under the 1994 Treaty of Mutual Legal
Assistance in Criminal Matters between the U.S. and the UK, as amended by the 16 December
2004 Instrument and exchange of notes ("the Treaty"). The United States Attorney for the
Southern District of New York and the Federal Bureau of Investigation (collectively the "U.S.
authorities") seek to interview H.R.H. Prince Andrew Albert Christian Edward, the Duke of York,
also known as Andrew Mountbatten-Windsor ("Prince Andrew" or "the witness"), relating to two
ongoing criminal investigations. In addition, U.S. authorities seek records of certain
communications and meetings between Prince Andrew and the subjects of one investigation.
With regard to the interview, U.S. authorities request to conduct a voluntary interview of
Prince Andrew and request the assistance of UK authorities in arranging for such an interview. In
the event that the witness declines to participate in a voluntary interview, U.S. authorities request
that UK authorities conduct a compelled interview of the witness under oath.
1
EFTA00022062

=== Page 2 ===
The U.S. authorities may use the requested records and information in the U.S. criminal
investigation and proceedings, as defined at Article 19 of the Treaty, and in other U.S. criminal
investigations and proceedings, as well as non-criminal judicial or administrative proceedings
directly related to the U.S. criminal investigations and proceedings, pursuant to Article 7 of the
Treaty.
CONFIDENTIALITY
The U.S. authorities are conducting ongoing criminal investigations. Notwithstanding
that one or more of the persons referenced in this request is aware to some extent of the U.S.
authorities' attention to this matter, this request also recounts specifics and evidentiary detail that
may not be known, exposure of which could impede the investigation with regard to the integrity
of evidence and witness accounts. Because the persons referenced in this request are generally
aware of the U.S. authorities' investigations, U.S. authorities are not requesting that the existence
of this legal assistance request be kept confidential. However, premature notification of the
specific subject matter and the questions outlined in the attachments to this request could seriously
jeopardize the investigations or compromise any trial, by prompting a witness to alter or prepare
his/her answers to specific questions, by prompting others to destroy or tamper with evidence;
change patterns of behavior; intimidate potential witnesses; or alert others who could do the same.
Accordingly, and pursuant to articles 4(3)(j) and 7 of the Treaty, please keep the contents of this
request, including the subject matter of questioning and the questions themselves, confidential and
please ensure that they are not shared with any persons (including the witness, the witness's
representatives, or subjects of the investigation), or with any government officials whose
knowledge is not absolutely necessary for purposes of executing this request. In addition, please
advise all who must be made aware of this request that the contents are to be kept confidential and
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should not be shared with any witness, potential subjects of the investigation or any other persons.
If this request cannot be executed without breaching such confidentiality, please notify U.S.
authorities through the U.S. Department of Justice, Office of International Affairs prior to taking
any action. U.S. authorities also request that UK authorities keep a written log of all those
individuals who have been made aware of the contents of this request, noting when those
individuals were so made aware.
THE FACTS
Investigation I: The Jeffrey Epstein Investigation
U.S. citizen Jeffrey Epstein is alleged to have engaged in the sexual abuse of minor girls
during the period of approximately 1994 through 2005. On or about July 2, 2019, a grand jury in
the Southern District of New York returned an Indictment charging Epstein with violations of
U.S. criminal laws in connection with his sexual abuse of minors, including with engaging in a
conspiracy to sexually traffic in minors. Epstein was arrested pursuant to the Indictment on or
about July 6, 2019, and had been detained pending trial in New York. On or about August 10,
2019, Epstein committed suicide in his cell. Notwithstanding Epstein's death, the investigation
that led to his indictment remains ongoing. That ongoing investigation has revealed evidence of
additional criminal conduct by Epstein's associates, including Ghislaine Maxwell.
The investigation to date has revealed that Prince Andrew may have been a witness to
and/or participant in certain events of relevance to the ongoing investigation. For example, one
victim has alleged that Maxwell introduced her to Prince Andrew who, according to this victim,
was present for certain of the victim's interactions with Epstein and Maxwell. Additionally,
documentary evidence uncovered during the course of this investigation has revealed
information suggesting that Prince Andrew had knowledge that Maxwell recruited females to
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engage in sex acts with Epstein and other men. Finally, there is evidence that Prince Andrew
engaged in sexual conduct involving one of Epstein's victims. Prince Andrew is not presently a
target of the investigation, and U.S. authorities have not, to date, gathered evidence that he has
committed any crime under U.S. law.
Investigation II: The Peter Nygard Investigation
The U.S. authorities are investigating Peter Nygard, a Canadian citizen, and other co-
conspirators' involvement in an international sex trafficking ring victimizing adult women and
minor girls. The investigation concerns, among other things, allegations of sex trafficking at
various locations inside and outside the United States, including Nygard's estate in Lyford Cay,
Bahamas, referred to as "Nygard Cay." Sex trafficking victims were transported internationally,
including between the Bahamas and locations in the United States.
The investigation of Peter Nygard and others is ongoing and no charges have been filed as
of this date. The investigation has revealed that, on at least one occasion, Prince Andrew travelled
to Nygard Cay in the Bahamas, a location where Nygard is believed to have trafficked minor and
adult female victims. U.S. authorities seek to question Prince Andrew regarding his visit(s) to
Nygard Cay during the time period under investigation, and other information he may have about
Peter Nygard and related individuals. Prince Andrew is not presently a target of this investigation,
and U.S. authorities have not, to date, collected evidence that he committed any crime under U.S.
law.
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THE OFFENSES
The criminal conduct being investigated currently implicates the following offenses. Note
that pursuant to Articles 7 and 19 of the Treaty, U.S. authorities may determine that additional or
different offenses may also be implicated in this matter:
Title 18, United States Code, Section 1591
Sex Trafficking of Minors and by Force,
Fraud, and Coercion
(a) Whoever knowingly -
(1) in or affecting interstate or foreign commerce, or within the special maritime
and territorial jurisdiction of the United States, recruits, entices, harbors,
transports, provides, obtains, advertises, maintains, patronizes, or solicits by
any means a person; or
(2) benefits, financially or by receiving anything of value, from participation in a
venture which has engaged in an act described in violation of paragraph (1),
knowing, or, except where the act constituting the violation of paragraph (1) is
advertising, in reckless disregard of the fact, that means of force, threats of
force, fraud, coercion described in subsection (e)(2), or any combination of
such means will be used to cause the person to engage in a commercial sex
act, or that the person has not attained the age of 18 years and will be caused
to engage in a commercial sex act, shall [have committed a crime].
(b) The punishment for an offense under subsection (a) is -
(1) if the offense was effected by means of force, threats of force, fraud, or
coercion or by any combination of such means, or if the person recruited,
enticed, harbored, transported, provided, obtained, advertised, patronized, or
solicited had not attained the age of 14 years at the time of such offense, by a
fine under this title and imprisonment for any term of years not less than 15 or
for life; or
(2) if he offense was not so effected, and the person recruited, enticed, harbored,
transported, provided, obtained, advertised, patronized, or solicited had
attained the age of 14 years but had not attained the age of 18 years at the time
of such offense, by a fine under this title and imprisonment for not less than
10 years or for life.¹
1 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that
occurred prior to that time, the penalties would be lower and may not include mandatory
minimum sentences.
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Title 18, United States Code, Section 2423
Transportation of Minors
(a) Transportation with intent to engage in criminal sexual activity
(1) A person who knowingly transports an individual who has not attained the age
of 18 years in interstate or foreign commerce, or in any commonwealth,
territory or possession of the United States, with intent that the individual
engage in prostitution, or in any sexual activity for which any person can be
charged with a criminal offense, shall [have committed a crime and be]
imprisoned not less than 10 years or for life.2
Title 18, United States Code, Section 2422
Coercion and Enticement
(1) (b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or
within the special maritime and territorial jurisdiction of the United States knowingly
persuades, induces, entices, or coerces any individual who has not attained the age of 18
years, to engage in prostitution or any sexual activity for which any person can be
charged with a criminal offense, or attempts to do so, shall [have committed a crime and
be] imprisoned not less than 10 years or for life.³
Title 18, United States Code, Section 371
Conspiracy
If two or more persons conspire to commit any offense against the United
States and one or more of such persons do any act to effect the object of the
conspiracy, each shall [have committed a crime and be] imprisoned not more than
five years.
PERSONS INVOLVED
Name:
H.R.H. Prince Andrew Albert Christian Edward, Duke of York
Also known as Andrew Mountbatten-Windsor
Date of birth:
19 February 1960
Place of birth:
Buckingham Palace, London, England
Citizenship:
UK
Address:
Royal Lodge, Windsor, England
2 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that
occurred prior to that time, the penalties would be lower and may not include mandatory
minimum sentences.
3 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that
occurred prior to that time, the penalties would be lower and may not include mandatory
minimum sentences.
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Name:
Ghislaine Maxwell
Date of Birth:
25 December 1961
Place of Birth:
Maison-Laffitte, France
Citizenship:
U.S., UK, France
Name:
Peter Nygard
Date of Birth:
24 July 1941
Place of Birth:
Helsinki, Finland
Citizenship:
Canada, Finland
ASSISTANCE NEEDED
Voluntary Interview Conducted by U.S. Authorities
U.S. authorities seek to conduct an investigative interview of Prince Andrew. U.S.
authorities specifically request to conduct the questioning themselves in the presence of UK
authorities to ensure that all necessary lines of inquiry are completed in the most efficient
fashion. The specific subject matters of questioning are set forth in Attachment A. U.S.
authorities further request that the interview be recorded using both video and audio recording
equipment. U.S. authorities request that at least two members of each of the following
investigatory teams be permitted to attend the questioning:
For Investigation I (Epstein):
a.
Assistant U.S. Attorney, Southern District of New York
b.
Assistant U.S. Attorney, Southern District of New York
c.
Assistant U.S. Attorney, Southern District of New York
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d.
Special Agent, Federal Bureau of Investigation
e.
Detective, New York City Police Department4
For Investigation II (Nygard):
a.
Assistant U.S. Attorney, Southern District of New York
b.
Assistant U.S. Attorney, Southern District of New York
c.
Assistant U.S. Attorney, Southern District of New York
d.
Special Agent, Federal Bureau of Investigation
e.
Detective, New York City Police Department5
If the witness requests, U.S. authorities are prepared to conduct the interview pursuant to a "proffer
letter" similar to that attached as Attachment B. The letter outlines the conditions under which
U.S. authorities will not use the witness's statements against him.
4 NYPD detective serving on the FBI task force, and assisting in the federal investigation.
5 NYPD detective serving on the FBI task force, and assisting in the federal investigation.
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Voluntary Interview Conducted by UK Authorities
In the event that UK authorities decline to permit the U.S. case team to directly question
the witness, U.S. authorities request that UK authorities question the witness about the subject
matters set forth in Attachment C. As noted on that list, U.S. authorities request that additional
follow-up questions be asked by UK authorities to clarify answers given or to follow relevant lines
of inquiry. In the event it would assist UK authorities, U.S. authorities will produce a list of
specific questions covering each of the topics outlined in Attachment C.
U.S. authorities also request to be present during the questioning of the witness by UK
authorities. Those observing would include at least two members of the teams listed above. U.S.
authorities also request that they be permitted to propose, during or at the conclusion of the
interview, additional questions to be asked by UK authorities of the witness after hearing the
witness's initial responses.
U.S. authorities request that UK authorities record the interview using audio and video
recording equipment. U.S. authorities further request that the witness be cautioned in the event of
a voluntary interview that if he were to provide false information to authorities in connection with
this mutual legal assistance request, he could be prosecuted for perverting the course of justice in
the UK, and he may be prosecuted for making a false statement, in violation of Title 18, United
States Code, Section 1001, in the U.S.
Compelled Interview
If the witness declines to participate in either type of voluntary interview requested above,
U.S. authorities request that UK authorities conduct a compelled interview under oath employing
the subject matters set out in Attachment C. As noted above, if it would assist UK authorities,
U.S. authorities will produce a list of specific questions covering each of the topics outlined in
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Attachment C. U.S authorities also request that the compelled interview be audio- or video-
recorded. If the witness declines to respond to questions by asserting his right to remain silent,
U.S. authorities request that such a declination be to each question set forth in Exhibit C and that
declination be on the audio or video recording under oath.
Prior to conducting the compelled interview, U.S. authorities request that the witness be
read the following caution on the record:
Pursuant to the 1994 Treaty of Mutual Legal Assistance in Criminal Matters between the
United States of America and the United Kingdom, as amended by the 16 December 2004
Instrument and exchange of notes, and [relevant provisions of UK domestic law], you have
been subpoenaed to answer questions under oath.
Authorities in the United States are conducting an investigation of possible violations of
Federal criminal laws including Sex Trafficking in violation of 18 United States Code
Section 1591, Transportation of Minors to Engage in Sex in violation of 18 United States
Code Section 2423, Coercion and Enticement of Minors to Engage in Sex in violation of
18 United States Code Section 2422, and related crimes.
You may refuse to answer any question if a truthful answer to the question would tend to
incriminate you.
Anything you do say may be used against you.
If you have retained counsel, you will be permitted a reasonable opportunity to consult
with counsel if you so desire.
Note that if you make any knowingly false statements you can be prosecuted for perverting
the course of justice and other related crimes under the laws of the United Kingdom.
Future Testimony
If the witness provides relevant information during the interview, the U.S. authorities
request that the witness be asked if he is willing to testify in U.S. criminal proceedings in the
Southern District of New York related to one or more of these investigation and any ensuing
prosecutions at some future date.
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Documents
U.S. authorities also seek certain records which are relevant to the Epstein Investigation.
In particular, the U.S. authorities request production of the following categories of
communication, including email, text, recorded or transcribed voicemail, and any other written
correspondence or notes of oral communications, which is in the custody or control of the
witness or his representatives:
a.
Any notes or calendar entries reflecting communications or meetings with
the following individuals: Jeffrey Epstein; Ghislaine Maxwell; or
b.
Any documents reflecting travel to the following locations: residence
located at 9 East 71st Street, New York, New York; "Zorro Ranch," located
in Santa Fe, New Mexico; 358 El Brillo Way, Palm Beach, Florida; any
other property owned or leased by Jeffrey Epstein or Ghislaine Maxwell.
c.
Any documents, such as receipts or tickets, reflecting events or meals at
which the following individuals were present: Jeffrey Epstein; Ghislaine
Maxwell; or
d.
Any communication to, from, or copying Ghislaine Maxwell involving the
following topics:
i.
ii.
Any females Maxwell, Jeffrey Epstein or any associate or
representative of Maxwell or Epstein arranged for Prince Andrew to
meet;
iii.
Any females Maxwell, Epstein or any associate or representative of
Maxwell or Epstein arranged for other adult men to meet.
iv.
Massage, massages, and/or masseuses.
V.
Any investigation into Epstein or is associates, including but not limited
to any prosecutions brought by the U.S. authorities against Epstein.
vi.
Any civil lawsuits threatened or brought against Prince Andrew,
Maxwell, Epstein, and/or their associates.
vii.
Any reference to or evidence of the destruction of evidence, the
obstruction of investigations, or other efforts to conceal criminal
activity by Epstein, Maxwell, or their associates.
viii.
Any payments made, in cash or in kind, to Maxwell, Epstein, or their
representatives or associates.
ix.
Any sexual encounters and/or romantic relationships involving Prince
Andrew and any female he met through Maxwell and/or Epstein.
X.
The involvement of Maxwell and/or any associate of Maxwell's in
recruiting, enticing, transporting or trafficking minors for the purpose
of engaging in unlawful sexual contact.
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e.
Any communication to, from, or copying Jeffrey Epstein involving the
following topics:
i.
ii.
Any females Epstein or his associates or representatives, including
Maxwell, arranged for Prince Andrew to meet.
iii.
Any females Epstein or his associates or representatives, including
Maxwell, arranged for other adult men to meet.
iv.
Massage, massages, and/or masseuses.
V.
Any investigation into Epstein or is associates or representatives,
including but not limited to any prosecutions brought by the U.S.
authorities against Epstein.
vi.
Any civil lawsuits threatened or brought against Prince Andrew,
Maxwell, and/or their associates.
vii.
Any reference to or evidence of the destruction of evidence, the
obstruction of investigations, or other efforts to conceal criminal
activity by Epstein, Maxwell, or their associates.
viii.
Any payments made, in cash or in kind, to Maxwell, Epstein, or their
representatives or associates.
ix.
Any sexual encounters and/or romantic relationships involving Prince
Andrew and any female he met through Maxwell and/or Epstein.
X.
The involvement of Epstein and/or any associate of Epstein's in
recruiting, enticing, transporting or trafficking minors for the purpose
of engaging in unlawful sexual contact
CONCLUSION
We thank you for your assistance with this matter of Material Witness PA and ask that
you keep us apprised of all developments.
3 April 2020
Date
Associate Director
Office of International Affairs
Criminal Division
U.S. Department of Justice
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ATTACHMENT A
The Jeffrey Epstein Investigation
The U.S. Authorities would seek to question Prince Andrew regarding the following
topics during a voluntary interview:
1. The history and nature of Prince Andrew's relationship with Jeffrey Epstein.
2. The history and nature of Prince Andrew's relationship with Ghislaine Maxwell.
3. The history and nature of Prince Andrew's relationship with
4. The details regarding any trips Prince Andrew took with and/or to visit Maxwell and/or
Epstein.
5. The details regarding any trips Maxwell and/or Epstein took to visit Prince Andrew.
6. The details regarding any payments Prince Andrew made to or received from Maxwell,
Epstein, or any female associated with Maxwell and/or Epstein.
7. The names and identifying features of any females Prince Andrew met through Epstein
and/or Maxwell.
8. The details of any conversations Prince Andrew participated in or witnessed during
which anyone discussed Epstein's sexual preferences, practices or history; Maxwell's
sexual preferences, practices, or history; and/or Maxwell's role assisting Epstein or other
men in locating females with whom to engage in sexual activity.
9. The details of Prince Andrew's interactions with and/or conversations regarding
10. Communications, including email correspondence, between Prince Andrew and Maxwell
regarding Maxwell's attempts to introduce Prince Andrew to females.
11. Any knowledge Prince Andrew had or may have had of inappropriate relationships,
including improper or unlawful sexual contact, involving Epstein and/or his associates
with any minor.
12. Prince Andrew's involvement, if any, in any sexual contact and/or relationship with any
person Prince Andrew met through or with Epstein and/or Maxwell.
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The Peter Nygard Investigation
1. The history and nature of Prince Andrew's relationship with Peter Nygard.
2. The details regarding any trips Prince Andrew took with and/or to visit Nygard.
3. The details of any trips Prince Andrew took to Nygard Cay, whether or not Nygard was
present.
4. The names and/or descriptions of any females Prince Andrew met through Nygard or at
Nygard Cay.
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ATTACHMENT B
PROFFER AGREEMENT
With respect to the meeting of
("Client") and his attorney,
,
Esq., with Assistant United States Attorney
to be held at the Office of the
United States Attorney for the Southern District of New York on [Meeting Date] ("the
meeting"), the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to
enter into a cooperation agreement, plea agreement, immunity or non-prosecution agreement.
The Government makes no representation about the likelihood that any such agreement will be
reached in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by
Client at the meeting, except (a) in a prosecution for false statements, obstruction of justice or
perjury with respect to any acts committed or statements made during or after the meeting or
testimony given after the meeting; or (b) if, at any time following the meeting, Client becomes a
fugitive from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information
derived directly or indirectly from the meeting for the purpose of obtaining leads to other
evidence, which evidence may be used in any prosecution of Client by the Government; (b) in
any prosecution brought against Client, the Government may use statements made by Client at
the meeting and all evidence obtained directly or indirectly therefrom for the purpose of cross-
examination should Client testify; and (c) the Government may also use statements made by
Client at the meeting to rebut any evidence or arguments offered by or on behalf of Client
(including arguments made or issues raised sua sponte by the District Court) at any stage of the
criminal prosecution (including bail, all phases of trial, and sentencing) in any prosecution
brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office
may offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in
evidence any statements made by Client or leads obtained therefrom, Client shall assert no claim
under the United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or
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any other federal rule that such statements or any leads therefrom should be suppressed. It is the
intent of this Agreement to waive all rights in the foregoing respects.
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such
information but will do so only on the condition that the requesting office honor the provisions of
this Agreement.
(7) It is further understood that this Agreement is limited to the statements made by
Client at the meeting and does not apply to any oral, written or recorded statements made by
Client at any other time. No understandings, promises, agreements and/or conditions have been
entered into with respect to the meeting other than those set forth in this Agreement and none
will be entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the
continuation of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand
every paragraph and clause in this Agreement and the consequences thereof.
Dated: New York, New York
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
by:
Client
Assistant United States Attorney
Attorney for Client
Witness
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ATTACHMENT
The Jeffrey Epstein Investigation
1. Please provide a list of all dates of travel or visits to any of the following locations:
a. An Epstein-owned property located at 358 El Brillo Way, Palm Beach, Florida
b. An Epstein-owned private island known as "Little St. James," located in the U.S.
Virgin Islands
c. An Epstein-owned mansion located at 9 East 71st Street, New York, New York
d. An Epstein-owned property known as "Zorro Ranch," located in Santa Fe, New
Mexico
2. For any dates provided for Question 1, please provide the following information:
a. Length of visit;
b. The names of any other individuals who were part of the visit, including family
members and security detail;
c. The names of any other individuals who were present at the property at the time;
d. Any related itineraries or schedules; and
e. Whether Prince Andrew observed any females who appeared to be, or stated that
they were, under the age of 18 years old, the names of any of those females, any
other observations Prince Andrew made of those females or conversations Prince
Andrew had or witnessed involving those females, and whether Prince Andrew
himself engaged in any sexual contact involving any of those females.
3. Please describe the history and nature of Prince Andrew's relationship with Ghislaine
Maxwell, including but not limited to how they met, how frequently they were in contact
during the general time period 1994-2005, how they communicated, and when they most
recently communicated.
4. Please describe the history and nature of Prince Andrew's relationship with Jeffrey
Epstein, including but not limited to how they met, how frequently they were in contact
during the general time period 1994-2005, how they communicated, and when they most
recently communicated.
5. Please describe the history and nature of Prince Andrew's relationship with
including but not limited to any sexual interactions between Prince
Andrew and
as well as the history and nature of any relationship between
and Maxwell, or
and Epstein.
6. Please identify the approximate date(s) of any oral or written communications between
Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or
representative for Ghislaine Maxwell and any agent, intermediary, and/or representative
for Prince Andrew at any time, regarding any of the following topics:
a. Females associated with Ghislaine Maxwell;
b. Females Ghislaine Maxwell or her representative arranged for Prince Andrew to
meet;
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c. Females Ghislaine Maxwell or her representative arranged for other adult men to
meet:
d.
e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein;
f. Massage, massages, and/or masseuses.
g. Any investigation into Epstein or his associates, including but not limited to any
prosecutions brought by the U.S. authorities against Epstein.
h. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, and/or
their associates.
i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or
otherwise cover up criminal activity by Epstein, Maxwell, or their associates.
j. Any payments Maxwell received or expected to receive from Epstein for
attorneys' fees or otherwise.
7. For any communications identified in response to Question 6, please provide the
following information:
a. Contact information, including phone numbers and email addresses for Ghislaine
Maxwell and/or any other individual acting as an agent, intermediary, and/or
representative for Ghislaine Maxwell;
b. Contact information, including phone numbers and email addresses for any
individual acting as an agent, intermediary, and/or representative for Prince
Andrew; and
c. Subject matter of the communications. Please be as detailed as possible. In
particular, please describe any communications regarding the following topics:
i. Females associated with Ghislaine Maxwell;
ii. Females Ghislaine Maxwell or her representative arranged for Prince
Andrew to meet;
iii. Females Ghislaine Maxwell or her representative arranged for other adult
men to meet;
iv.
V. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein;
vi. Massage, massages, and/or masseuses.
vii. Any investigation into Epstein or his associates, including but not limited
to any prosecutions brought by the U.S. authorities against Epstein.
viii. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell,
and/or their associates.
ix. Any attempts to destroy evidence, obstruct or impede ongoing
investigations, or otherwise cover up criminal activity by Epstein,
Maxwell, or their associates.
X. Any payments Maxwell received or expected to receive from Epstein for
attorneys' fees or otherwise.
8. Please identify the approximate date(s) of any oral or written communications between
Jeffrey Epstein or any other individual acting as an agent, intermediary, and/or
representative for Jeffrey Epstein and any agent, intermediary, and/or representative for
Prince Andrew at any time, regarding any of the following topics:
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a. Females associated with Jeffrey Epstein;
b. Females Jeffrey Epstein or his representative arranged for Prince Andrew to meet;
c. Females Jeffrey Epstein or his representative arranged for other adult men to
meet;
d.
e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein;
f. Massage, massages, and/or masseuses.
g. Any investigation into Epstein or his associates, including but not limited to any
prosecutions brought by the U.S. authorities against Epstein.
h. Any civil lawsuits threatened or brought against Epstein and/or his associates.
i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or
otherwise cover up criminal activity by Epstein, Maxwell, or their associates.
j. Any payments Epstein made or intended to make to Maxwell for attorneys' fees
or otherwise.
9. For any communications identified in response to Question 8, please provide the
following information:
a. Contact information, including phone numbers and email addresses for Jeffrey
Epstein and/or any other individual acting as an agent, intermediary, and/or
representative for Jeffrey Epstein;
b. Contact information, including phone numbers and email addresses for any
individual acting as an agent, intermediary, and/or representative for Prince
Andrew; and
c. Subject matter of the communications. Please be as detailed as possible. In
particular, please describe any communications regarding the following topics:
i. Females associated with Jeffrey Epstein;
ii. Females Jeffrey Epstein or his representative arranged for Prince Andrew
to meet;
iii. Females Jeffrey Epstein or his representative arranged for other adult men
to meet;
iv.
;
V. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein;
vi. Massage, massages, and/or masseuses.
vii. Any investigation into Epstein or his associates, including but not limited
to any prosecutions brought by the U.S. authorities against Epstein.
viii. Any civil lawsuits threatened or brought against Epstein and/or his
associates.
ix. Any attempts to destroy evidence, obstruct or impede ongoing
investigations, or otherwise cover up criminal activity by Epstein,
Maxwell, or their associates.
X. Any payments Epstein made or intended to make to Maxwell for
attorneys' fees or otherwise.
10. Please identify the approximate date(s) of any oral or written communications between
or any other individual acting as an agent, intermediary, and/or
3
SBU-LAW ENFORCEMENT
EFTA00022080

=== Page 20 ===
representative for
and any agent, intermediary, and/or
representative for Prince Andrew
11. For any communications identified in response to Question 10, please provide the
following information:
a. Contact information, including phone numbers and email addresses for
and/or any other individual acting as an agent, intermediary,
and/or representative for
b. Contact information, including phone numbers and email addresses for any
individual acting as an agent, intermediary, and/or representative for Prince
Andrew; and
c. Subject matter of the communications.
d. Nature of Prince Andrew's interactions with
12. Please identify the approximately date(s) and locations of any meetings or other
interactions with
including the nature and/or purpose of the
meeting, the approximate duration of the meeting, the name(s) of any other persons
present for the meeting, and a detailed account of what occurred at the meeting.
13. Please identify any payments made, in any form including by cash or in kind, to Prince
Andrew by Ghislaine Maxwell or any other individual acting as an agent, intermediary,
and/or representative for Ghislaine Maxwell. Please include travel, lodging, or other
expenses paid in connection with any trip to visit Ghislaine Maxwell.
14. Please identify any payments made, in any form including by cash or in kind, to
Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or
representative for Ghislaine Maxwell from or on behalf of Prince Andrew.
15. Please identify any payments made, in any form including by cash or in kind, to Prince
Andrew by Jeffrey Epstein or any other individual acting as an agent, intermediary,
and/or representative for Jeffrey Epstein. Please include travel, lodging, or other
expenses paid in connection with any trip to visit Jeffrey Epstein.
16. Please identify any payments made, in any form including by cash or in kind, to Jeffrey
Epstein or any other individual acting as an agent, intermediary, and/or representative for
Jeffrey Epstein well from or on behalf of Prince Andrew.
17. Please identify any payments made, in any form including by cash or in kind, to
or any other individual acting as an agent, intermediary, and/or
representative for
well from or on behalf of Prince Andrew.
18. Please identify any payments made, in any form including by cash or in kind, to any
female Prince Andrew met through Ghislaine Maxwell and/or Jeffrey Epstein, or any
other individual acting as an agent, intermediary, and/or representative for any such
female from or on behalf of Prince Andrew.
4
SBU-LAW ENFORCEMENT
EFTA00022081

=== Page 21 ===
19. Please identify any sexual encounters and/or romantic relationships involving Prince
Andrew and any female he met through Maxwell and/or Epstein. In particular, please
describe how Prince Andrew met any such female and detail any communications Prince
Andrew had regarding any such female with Maxwell, Epstein, and/or any associates of
Maxwell and/or Epstein.
20. Please provide any information, based on, among other things, any of the interactions or
communications responsive to any question above, about the involvement of Jeffrey
Epstein and/or any associate of Epstein's in recruiting, enticing, transporting or
trafficking minors for the purpose of engaging in unlawful sexual contact.
The Peter Nygard Investigation
1. Please provide a list of all dates of travel or visits to any of the following locations:
a. Nygard Cay, Bahamas
b. Lyford Cay, Bahamas
c. 1 Yawl Street, Marina Del Rey, CA
d. 17 Yawl Street, Marina Del Rey, CA
e. 1435 Broadway, New York, New York
2. For any dates provided for Question 1, please provide the following information:
a. Length of visit;
b. The names of any other individuals in party, including family members and
security detail;
c. The names of any other individuals who were present at the property at the time;
d. Any related itineraries or schedules; and
e. Whether Prince Andrew observed any females who appeared to be, or stated that
they were, under the age of 18 years old, and the names of any of those females.
3. Please identify the approximate date(s) of any oral or written communications between
Peter Nygard or any other individual acting as an agent, intermediary, and/or
representative for Peter Nygard and any agent, intermediary, and/or representative for
Prince Andrew.
4. For any communications identified in response to Question 3, please provide the
following information:
a. Contact information, including phone numbers and email addresses for Peter
Nygard and/or any other individual acting as an agent, intermediary, and/or
representative for Peter Nygard;
b. Contact information, including phone numbers and email addresses for any
individual acting as an agent, intermediary, and/or representative for Prince
Andrew; and
c. Subject matter of the communications. Please be as detailed as possible.
5. Please identify any payments made, in any form including by cash or in kind, to Prince
Andrew by Peter Nygard or any other individual acting as an agent, intermediary, and/or
5
SBU-LAW ENFORCEMENT
EFTA00022082

=== Page 22 ===
representative for Peter Nygard. Please include travel, lodging, or other expenses paid in
connection with any visit to Nygard Cay, Bahamas.
6. Please identify any payments made, in any form including by cash or in kind, to Peter
Nygard or any other individual acting as an agent, intermediary, and/or representative for
Peter Nygard from or on behalf of Prince Andrew.
6
SBU-LAW ENFORCEMENT
EFTA00022083


c1: EFTA00021177
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021177.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: CBP Question
Date: Tue, 21 Sep 2021 16:13:30 +0000
Attachments: JE_1.21.2000.pdf; JE_12.11.1999.pdf;JE_Travel_1.1.1997_to_2.1.2000.pdf
GM_1.21.2000.pdf; GM_6.23.1997.pdf; GM_7.20.1998.pdf,GM_7.24.1998.pdf
GM_8.6.1997.pdf; GM_12.18.1999.pdf; GM_Travel_1.1.1997_to_2.1.2000.pdf
Hi
Could you please double check that we've already produced the attached records in discovery? For any record you can't
easily verify that we've already produced, please add it to the next production.
Thanks!
From:
Sent: Tuesday, September 21, 2021 12:09 PM
To:
Cc:
Subject: RE: CBP Question
Hi
I ran travel for both Maxwell and Epstein between 1/1/1997 to 2/1/2000.
After reviewing the travel details, the dates that correlate or are near the dates listed for
are listed below. These
are listed as INBOUND records.
Jeffrey Epstein:
12/11/1999
1/21/2000
Ghislaine Maxwell
6/23/1997
8/6/1997
7/20/1998
7/24/1998
12/18/1999
1/21/2000
I
included 6/23/1997 and 8/6/1997 because between those dates GM traveled OUTBOUND. The same for 7/20/1998-
7/24/1998.
I attached each individual records as well as the full travel records for 1/1/1997-2/1/2000.
Thanks,
EFTA00021177

=== Page 2 ===
From:
Sent: Monday, September 20, 2021 10:55 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - FW: CBP Question
Hi
Could you please take a look at these and let us know if any of these dates line up with Maxwell or Epstein's travel?
Thanks!
From:
Sent: Monday, September 20, 2021 10:49 PM
To:
Cc:
Subject: [EXTERNAL] RE: CBP Question
Hey
Attached ate the travel records as requested. However, it's the same issue as last time since the outbound departures
were not recorded during that timeframe it only shows the inbound arrivals. Any questions or concerns don't hesitate to
reach out.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws
including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and
destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may
be disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Monday, September 20, 2021 2:11 PM
To:
EFTA00021178

=== Page 3 ===
Cc:
Subject: RE: CBP Question
Thanks so much! Can you please pull the CBP records for
?
We would like the CBP records for the 1990s
only. Her date of birth is
She is French. Please let us know if you need any other information. Thanks again!
From:
Sent: Monday, September 20, 2021 1:50 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sure no problem, send over the info you need and I'll work on it today.
Sent from my iPhone
On Sep 20, 2021, at 1:42 PM,
wrote:
Hi
I hope you are doing well. We were hoping you could pull some additional CBP records for us. Are you able to assist us
with that this week?
Thanks so much,
From:
Sent: Thursday, July 29, 2021 5:31 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sorry I was on the road but I spoke with
he filled me in on what your looking for. I'm also available for a call to
further discuss.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
EFTA00021179

=== Page 4 ===
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable
laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the
sender and destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be
disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Thursday, July 29, 2021 3:56:15 PM
To:
Cc:
Subject: CBP Question
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option.
Hi
I hope you are well!
passed along your info to us. We were hoping to connect with you by phone about
a question in one of our cases. Do you have time to talk today or tomorrow morning?
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00021180


c1: EFTA00023154
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023154.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 17:27:16 +0000
Hello
-
said she has time tomorrow if that would work for you team. She is in Texas so an hour behind us.
I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From:
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
EFTA00023154

=== Page 2 ===
Best,
Sigrid
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To:
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day -whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
)
Sent: Thursday, January 16, 2020 14:35
To:
Cc:
is
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
EFTA00023155

=== Page 3 ===
New York, NY 10007
From:
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much,
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023156

=== Page 4 ===
From:
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To:
Cc:
)
i
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023157

=== Page 5 ===
From:
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To:
Cc:
)
i
)
Subject:
follow-up request
Hi
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
EFTA00023158

=== Page 6 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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
EFTA00023159


c1: EFTA00020852
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020852.pdf
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c7: images
c0:
=== Page 1 ===
From:
)"
To: "McGorty, Glen"
)"
Cc: "Zelenko, Daniel"
"Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Wed, 18 Nov 2020 02:30:22 +0000
Received, thank you very much, Glen.
Best,
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Tuesday, November 17, 2020 8:21 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
--- sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com I Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Wednesday, November 11, 2020 1:43 PM
To: McGorty, Glen
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
EFTA00020852

=== Page 2 ===
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I expect one
of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those traveling with
Epstein to enter the country, including any steps that allowed Epstein or those traveling with him to avoid
processing that travelers would normally undergo.
Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Tuesday, November 10, 2020 1:16 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
EFTA00020853

=== Page 3 ===
From:
Sent: Monday, October 26, 2020 6:19 PM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Monday, October 26, 2020 11:58 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
-
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
EFTA00020854

=== Page 4 ===
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Thursday, October 22, 2020 10:33 AM
To:
>; ; McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Friday, October 9, 2020 4:42 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From: McGorty, Glen
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
EFTA00020855

=== Page 5 ===
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 5, 2020 4:14 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
is
)
Subject: RE: Wednesday's WebEx
External Email
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From: McGorty, Glen
Sent: Monday, October 5, 2020 12:48 PM
To:
is
)
is
(USANYS)
Cc: Zelenko, Daniel
is
>; ; Giffuni, Danielle
Morrissey, Josh
Subject: Wednesday's WebEx
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan, Danielle
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
Glen
EFTA00020856

=== Page 6 ===
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
4
www.crowell.com
I
Web Bio
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EFTA00020857


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=== Page 1 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 1 of 14
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
CASE NO:
V.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
COMPLAINT
BOIES SCHILLER FLEXNER LLP
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=== Page 2 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 2 of 14
Plaintiff Jane Doe 1000, by her attorneys Boies Schiller Flexner LLP, for her Complaint
against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of
the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own
acts and status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
1.
This suit arises out of Jeffrey Epstein's sexual abuse of Plaintiff.
2.
Jane Doe 1000 was sexually trafficked by Epstein as part of his organized ring of
procuring young and underage girls for sex. One of Epstein's co-conspirators contacted Jane
Doe after a modeling appearance and arranged to have Jane Doe meet Epstein under the false
pretense that he was involved in the modeling industry and wanted to interview her about
opportunities. Rather than help her with her modeling career, Epstein manipulated and
intimidated Jane Doe and subjected her to years of sexual abuse in his New York mansion.
3.
Epstein's trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4.
As United States District Judge Kenneth Marra found, "From between about 1999 and
2007, Jeffrey Epstein sexually abused more than 30 minor girls
at his mansion in Palm Beach
Florida, and elsewhere in the United States and overseas.
In addition to his own sexual abuse
of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
minors not only for his own sexual gratification, but also for the sexual gratification of others."
Doe 1 V. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
2
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=== Page 3 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 3 of 14
5.
Epstein organized this sex trafficking network to obtain hundreds of young females for
himself for sex, and also lent these females out to other powerful and wealthy individuals to be
sexually abused.
6.
Epstein conspired with others and hired staff to maintain and keep secret this network of
sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida,
New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three
different young females a day for his sexual pleasure.
7.
Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal
charge pleading guilty to a single Florida state law charge of procuring a minor for prostitution
and a non-prosecution agreement (a "NPA") with the U.S. Attorney for the Southern District of
Florida. Unknown to the public and the victims at the time, Epstein's lawyers were pressuring
the Government to commit to the NPA without informing the victims. Epstein's multiple
victims were kept in the dark and told to be "patient" while Epstein's lawyers worked to protect
him and other potential co-conspirators from prosecution. Epstein served one year in jail, but
was afforded the privilege of being able to leave the jail to go to work for twelve hours per day,
six days per week.
8.
The NPA allowed Epstein to escape proportionate punishment for his actions and to
continue operating his sex trafficking enterprise with liberty.
9.
A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and
the slap on the wrist he had received for it, in a 2011 interview with the New York Post:
"Billionaire pervert Jeffrey Epstein is back in New York City - and making wisecracks about his
just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an
offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a
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=== Page 4 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 4 of 14
person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a
Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011),
https://nypost.com/2011/02/25/billionaire-jeffey-epstein-im-a-sex-offender-not-a-predator/
10.
In August 2018, just one year before his death, Epstein told a New York Times reporter
"that criminalizing sex with teenage girls was a cultural aberration and that at times in history it
was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on
Powerful People, N.Y. Times (Aug. 12, 2019),
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
11.
When Plaintiff was a young woman, Epstein added her to his long list of victims by
committing sexual assault and battery against her. As such, Epstein is responsible for battery
and intentional infliction of emotional distress pursuant to New York common law. The damage
to Plaintiff has been severe and lasting.
12.
This action has been timely filed pursuant to N.Y. C.P.L.R. $ 215(8)(a), which provides
that a plaintiff shall have at least one year from the termination of a criminal action against the
same defendant to commence an action with respect to the event or occurrence from which the
criminal action arose. A criminal action against Epstein with respect to the same sex trafficking
enterprise from which Plaintiff's claims arise was terminated on August 29, 2019.
13.
This action has also been timely filed pursuant to N.Y. C.P.L.R. $ 213-C, which provides
that a plaintiff shall have 20 years to file civil claims "for physical, psychological or other injury
or condition suffered by such person as a result of conduct which would constitute" certain sex
crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually
assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that
sexual assault constitutes one or more sex crimes described in N.Y. C.P.L.R. $ 213-C.
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=== Page 5 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 5 of 14
14.
Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, and other forms of misconduct that
Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein's
actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his
death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin
her life, if she came forward.
15.
Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each
of his victims into silence by threatening their lives and their livelihoods. They therefore
prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with
his wealth and power, Epstein was able to escape punishment for his intolerable and brutal
crimes against countless young women and underage girls for the duration of his life.
PARTIES
16.
Plaintiff Jane Doe 1000 is a citizen and resident of New Jersey.
17.
Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
18.
Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
19.
Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at
the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New
York. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and
Richard D. Kahn are deemed citizens of the U.S. Virgin Islands.
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=== Page 6 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 6 of 14
20.
The amount in controversy in this action exceeds the sum or value of $75,000.00
excluding interests and costs and is between citizens of different states. Accordingly, jurisdiction
is proper under 28 U.S.C. $ 1332.
21.
Venue is proper in this Court as Epstein's sexual abuse of Plaintiff began and occurred in
New York, New York, where he recruited her, physically molested her, and began grooming her
for sex in his organized sex trafficking ring.
22.
Many of the events giving rise to these causes of action occurred in the Southern District
of New York, where a substantial amount of Epstein's property is located. Thus, venue in this
district is proper. 28 U.S.C. $ 1391(b)(2).
FACTUAL ALLEGATIONS
A.
Epstein's Sex Trafficking Enterprise
23.
Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to
powerful individuals, and seemingly unlimited wealth and resources, to create a web of
transcontinental sex trafficking that served himself, his coconspirators, and some of the most
powerful people in the world.
24.
Epstein owned multiple residences and frequently travelled between them, including at 9
East 71st Street, New York, New York 10021, where the illegal sexual crimes against Plaintiff
occurred. Epstein conservatively valued his New York townhome at $55,931,000.00. Epstein
conservatively valued his ranch at 49 Zorro Ranch Road, Stanley, New Mexico 87056, at
$17,246,208.00. In addition, Epstein owned residences in the Virgin Islands, Florida, France,
and even on his own island, Great St. James Island, where his transcontinental sex trafficking of
hundreds of young girls servicing him, his co-conspirators, and wealthy and powerful individuals
around the world occurred.
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=== Page 7 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 7 of 14
25.
The allegations herein concern Epstein's tortious acts against Plaintiff while in New
York, where Epstein was staying at his mansion.
26.
At all times material to this cause of action, Jeffrey Epstein utilized his seemingly
unlimited power, wealth, and resources, as well as his deep connections to powerful and
politically connected individuals to intimidate and manipulate his victims of sexual abuse.
27.
Epstein and his co-conspirators had perfected a scheme for manipulation and abuse of
young females. As part of the scheme, a female "recruiter" would approach a young female and
strike up a conversation in an effort to quickly learn about the young female's background and
any vulnerabilities they could expose. The recruiter would then manipulate the young female
into coming back to one of Epstein's residences by offering the young female something she
needed. At times the recruiter's lure would be a modeling opportunity, money for education,
help for the young female's family, and a whole host of other related offers depending on their
target's situation. Once in the residence, the recruiter and Epstein would work in concert to
impress and intimidate the young female with displays of vast wealth, including having
employees that were butlers and maids formally dressed around the house. They would also
strategically place photographs of very powerful political and social figures amongst
photographs and art displaying nude females in an effort to normalize the sexual abuse. They
would also normalize the sexual abuse by placing a massage table and spa related products
around the massage area in an effort to legitimize the area where the abuse was set to occur.
Once abused, Epstein and his co-conspirators continued to manipulate the victims, using their
financial power, promises, and threats to ensure that the victim returned as directed and remained
compliant with their demands.
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=== Page 8 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 8 of 14
B.
The Arrest, Prosecution, and Death of Epstein
28.
The sexual trafficking ring described herein started at least as early as 1995 and
continued up until at least July 2, 2019, when the U.S. Attorney's Office for the Southern District
of New York ("SDNY") charged Epstein with sex trafficking conspiracy and sex trafficking in
violation of 18 U.S.C. $ 1591. He was arrested on July 8, 2019, pursuant to the SDNY's Sealed
Two Count Indictment, which is attached as Exhibit A.
29.
The Indictment described Epstein's conduct and his abuse and trafficking of females in
the same trafficking operation he used to abuse and traffic Plaintiff.
30.
Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the
Metropolitan Correctional Center. The witnesses were Mariel Colón Miró and Gulnora Tali. The
Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an
"Oath of Willingness to Serve as Executor and Appointment of Local Counsel."
31.
Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10,
2019.
32.
Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of
the Superior Court of the Virgin Islands.
33.
Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court
of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In
the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26,
2019).
34.
Epstein's will was entered into probate on September 6, 2019, and the Superior Court of
the Virgin Islands accordingly authorized Darren K. Indyke and Richard D. Kahn to administer
Epstein's estate. See Order for Probate, In the Matter of the Estate of Jeffrey E. Epstein, Probate
8
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=== Page 9 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 9 of 14
No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the
Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019).
35.
The Will's first article directs Epstein's executors "to pay from my estate all expenses of
my last illness, my funeral and burial expenses, the administration expenses of my estate and all
of my debts duly proven and allowed against my estate." The Will further directs that "after the
payments and distributions provided in Article FIRST," Epstein "give[s] all of my property, real
and personal, wherever situated to the then acting Trustees of The 1953 Trust."
36.
Following Epstein's death, SDNY submitted a proposed nolle prosequi order in the
criminal matter against him because it was required by law to do so after Epstein was deceased.
On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's
indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are
therefore timely under N.Y. C.P.L.R. $ 215(8)(a).
C.
Jane Doe 1000
37.
Jane Doe 1000 grew up in extreme poverty. At various times throughout her childhood,
her mother had been homeless. Jane Doe was unable to enroll in high school because she did not
have a residence and often lived without running water or electricity.
38.
In late 1999, Jane Doe made a modeling appearance. A man called her and told her that
Jeffrey Epstein had connections to various modeling jobs and asked her if she would like to meet
with Epstein to discuss opportunities. The opportunity sounded enticing to Jane Doe, so she
agreed and met Epstein at his New York City mansion on 71st Street.
39.
Upon meeting Jane Doe, Epstein offered her a position modeling with Victoria's Secret, a
lingerie retailer. He explained that he was friends with Les Wexner, the chief executive of
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=== Page 10 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 10 of 14
Victoria's Secret's parent company. Epstein reiterated his connection to Victoria's Secret each
time he saw and spoke with Jane Doe.
40.
Eventually, Epstein moved Jane Doe into his apartment building on 66th Street, where he
housed other models and young women that he sexually abused, so that he could have complete
control over her life. Her relationship with Epstein quickly turned into one of sexual abuse.
Ghislaine Maxwell, one of Epstein's main "recruiters," along with additional unidentified
co-conspirators, would call Jane Doe and direct her to go to Epstein's mansion to give him a
massage. The massages quickly escalated into Epstein forcing himself on Jane Doe against her
will and engaging in one or more sex act with her for his own sexual gratification. Jane Doe was
terrified of Epstein, who repeatedly threatened her and made representations about his wealth,
power, and connections.
41.
During Jane Doe's time with Epstein, he forced her to give him sexual massages and
made her use sex toys.
42.
Epstein also flew Jane Doe to his residence in Palm Beach, Florida, where she was also
forced to give Epstein sexual massages.
43.
On one occasion, Epstein forced Jane Doe to meet with a lawyer, even though she did not
express any need for a lawyer to Epstein. The lawyer she met with was a prominent attorney and
a law professor who was described to Jane Doe as Epstein's close friend and lawyer. The
lawyer appeared to be interviewing her, asking personal questions about her family's financial
situation. The meeting had no legal purpose, and Epstein later used the information that the
lawyer had obtained through his meeting with Jane Doe to intimidate her and to keep her
compliant in his sex-trafficking scheme.
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=== Page 11 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 11 of 14
44.
Epstein made very clear to Jane Doe that he was incredibly wealthy, powerful and
regularly in contact with world leaders. In fact, in his New York mansion he had photographs
displayed of significant political figures to ensure that any young female entering the home
would know that he had extensive government connections. Epstein was not to be disobeyed and
he made clear by his words and actions that there would be consequences if Jane Doe did not
comply with his demands.
45.
Epstein constantly promised Jane Doe modeling opportunities with Victoria's Secret each
time she saw him. He continued to make that promise for years, up until the last time Jane Doe
saw Epstein.
46.
One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived,
Maxwell was waiting for her and led her upstairs to Epstein's master bedroom. When they got to
the bedroom, sex toys were laid out on the bed. Epstein and Maxwell proceeded to sexually
assault Jane Doe simultaneously and by forcible compulsion. Maxwell forcibly penetrated Jane
Doe with a sex toy. She was horrified and terrified by the experience and knew she had to try to
get away from Epstein even though she risked harm to herself by disobeying Epstein. She
proceeded to move out of the 66th Street apartment building and, having nowhere else to go,
found shelter at the Salvation Army housing facility.
47.
Jane Doe was deeply affected by her harrowing experiences at the hands of Epstein. She
suffers extreme emotional distress from an experience that has affected her for her entire life.
48.
Epstein's sexual assault and battery of Jane Doe continues to cause her significant
distress and harm.
11
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=== Page 12 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 12 of 14
FIRST CAUSE OF ACTION
(Battery)
49.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-48 as if fully
set forth herein.
50.
Epstein intentionally committed battery by sexually assaulting Plaintiff when she was a
young woman. As described above, on multiple occasions, Epstein intentionally sexually
assaulted and touched Plaintiff in an offensive and sexual manner without her consent.
51.
Epstein's actions constitute sexual offenses as defined in New York Penal Law Article
130, including but not limited to Article 130.35, inasmuch as Epstein and Maxwell sexually
assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint. See N.Y.
C.P.L.R. $ 213-C.
52.
A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiff's first cause of action arises was terminated on August 29, 2019, less than one
year prior to the filing of this Complaint. See N.Y. C.P.L.R. $ 215(8)(a).
53.
As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in
the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma,
loss of dignity and self-esteem, and invasion of her privacy.
SECOND CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
54.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-48 as if fully
set forth herein.
55.
As a direct result of these allegations as stated, Epstein committed intentional infliction of
emotional distress against Plaintiff.
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=== Page 13 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 13 of 14
56.
Epstein's actions, described above, constitute extreme and outrageous conduct that
shocks the conscience. Epstein's plan to recruit, entice, and assault Plaintiff on multiple
occasions goes beyond all possible bounds of decency and is intolerable in a civilized
community.
57.
Epstein knew or disregarded the substantial likelihood that these actions would cause
Plaintiff severe emotional distress.
58.
A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiff's second cause of action arises was terminated on August 29, 2019, less than one
year prior to the filing of this Complaint. See N.Y. C.P.L.R. $ 215(8)(a).
59.
As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in
the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma,
loss of dignity and self-esteem, and invasion of her privacy.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment against Defendants, awarding
compensatory, consequential, exemplary, and punitive damages in an amount to be determined at
trial; costs of suit; attorneys' fees; and such other and further relief as the Court may deem just
and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all causes of action asserted within this
pleading.
13
EFTA00023304

=== Page 14 ===
Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 14 of 14
Dated: November 14, 2019.
/s/ Joshua I. Schiller
David Boies
BOIES SCHILLER FLEXNER LLP
333 Main Street
Armonk, NY 10504
(914) 749-8200
Joshua I. Schiller
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards
New York, NY 10001
(212) 446-2300
Sigrid McCawley
(Pro Hac Vice Pending)
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
14
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=== Page 1 ===
From: Jean James <j
To: Undisclosed recipients:;
Bcc: "Berman, Geoffrey (USANYS)"
Subject: Fwd: Some inside info on Russian Money laundering and the Epstein paedophile ring
Date: Mon, 16 Dec 2019 03:45:32 +0000
Mr. Taylor appears optimistic, but I can assure you that he will be ignored. The NCA works only for the
Home Office and not the taxpayer. It is not a crime reporting agency. Neither is the SFO. The rest of
the British police forces will not investigate serious economic crime unless pushed to do so by
politicians or important people.
This is why these types of crimes continue under the radar, and are affecting other nations and the
global economy.
Jean James
From: "TheAbstraction
To: "lynne owens"
Cc: "info"
Sent: Sunday, 15 December, 2019 12:12:24
Subject: Some inside info on Russian Money laundering and the Epstein paedophile ring
Kalamata
Billington Lane
Derrington
Stafford
ST18 9LR
15 Dec 2019
To Lynn Owens of the NCA:
Dear Director General Lynn Owens,
I wish to report serious matters of fraud, particularly those involved with Russian money
laundering of gold bullion and their links to the Epstein paedophile ring which I believe is blackmailing
Parliament. This email will serve to prove I did my civil duty and reported the crime at the highest level.
I believe the Foreign Office had previously obstructed the NCA's investigations in these matters in
2018, but this was under Theresa May, so perhaps you are now free to re-open the investigation.
The possibility that gold bullion was used in the Laundromat Russian money laundering operation
was raised by me in 2015 in the Birmingham Mercantile Court in lawsuit B40BM021. I had drawn the
conclusion after reading of Deutsche Bank's $10 billion money laundering operation in the New Yorker
for which they were later fined by the FCA in 2016. Deutsche Bank's conduct in my lawsuit suggested
to me that they had destroyed bullion trading receipts, and that this incriminated executives in both
auditing fraud and money laundering. It has not hard to put these two facts together.
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=== Page 2 ===
I believe that DB's position was so untenable it had to bribe a number of judges, regulator executives
and politicians to make sure that no court or other agency would force disclosure of my receipts.
Simon Brown QC, the judge in my first hearing ended up the butt of three sets of appeals, in which he
was found guilty of gross misconduct and perverse verdicts. In each case the victim of his judgement
was financially vulnerable and the opposing party of significant wealth.
Unfortunately my attempt at an appeal was blocked by Lord Chief Justice Sir lan Burnnet who
refused me permission. The grounds of appeal clearly set out a case of corruption and required a
transcript of hearing. Burnett closed the appeal without such a transcript, which was confirmed by the
ICO after 6 months of obstruction from the judiciary.
Burnett's decision had two effects - first it hid Deutsche Bank's gold and sivler manipulation from the
public eye - until it was exposed in New York under Judge Valerie E Caproni. Secondly, by covering up
destruction of bullion trading receipts it hid DB's involvement in the Dankse operation
Asit turns out that Danske bank, via its Estonian branch, was using Deutsche Bank to underwrite its
trades to the Russian Mafia, and this includes selling bullion without seals, certificates or receipts.
It does not take too much imagination to see that if Danske had laundered as little as $1 billion in
bullion that this would create serious accounting problems in DB's bullion inventories. The easiest way
to conceal the degree of this fraud is to destroy en masse bullion trading receipts.
In the court all judges refused to force DB to disclose my receipts - which is an outrageous violation
of my Data Protection Rights and basic rights to a fair trial - as I was accused of not being able to
quantify damages - even as defendants have refused to hand over receipts for such quantification,
The ICO spent 15 months obstructing my SAR to DB for the receipts. Only by forceful
correspondence from my constituency MP, Jeremy Lefroy, did they provide a response - and that was
to refuse to hand over the receipts, citing a technicality in German Law.
The FCA and the SFO refuse to investigate. It is quite obvious that all with the authority and power
to force disclosure of receipts have been paid off not to do their duty.
I have subsequently discovered that both Deutsche Bank and Barclays (also a defendant in my
lawsuit) were involved in laundering money for Jeffrey Epstein. Epstein had blackmailed Parliament to
put Jes Staley in charge of Barclays. This is established in a response from Parliament to a FOIA from
me in which the Treasury Select Committee admit to having the blackmail emails.
The fact that Staley is still in charge of Barclays tells us that the blackmail operation is still in effect
and Staley is capable of corrupting the FCA, the PRA and the FRC, all of which have a duty to expel
Staley from Barclays for his record with Epstein.
Staley had threatened me with a restraining order and costs should I take Deutsche Bank to court.
I
also believe there is a very strong possibility that my friend Katherine Frisk, was murdered by Staley's
operators to cover up the blackmail operation and she died in mysterious circumstances merely 48
hours after publishing the material on Staley in the International Reporter. Given that the FBI had told
that she is at risk of assassination for exposing the same blackmail ring, that
possibility must be taken seriously.
My lawsuit alleged manipulation of gold and silver prices, which has been proven true in subsequent
settlements, prosecutions and fines against UBS, HSBC, JP Morgan and Deutsche Bank.
The key evidence is linked here - it shows DB's public statements about its audits contradicted what
it sent to me. The FCA refuse to press DB for an explanation, as do the courts.
EFTA00022174

=== Page 3 ===
http://www.shyreman.com/docs/claim.bundle/evidence.for.fake.gold.audit.pdf
Clearly if the NCA's investigation could be quashed by Staley and CO, every agency with a parallel
investigation had to be compromised.
It appears that Action Fraud, the ICO and the FCA all have a 95-99% disapproval rating. I hope the
NCA can do better.
Regards
Mark Anthony Taylor
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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Fri, 07 Feb 2020 14:34:22 +0000
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.
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.
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From:
(USANYS)"
To:
(USANYS)"
Bcc:
(USANYS)"
Subject: Jeffrey Epstein on suicide watch after injury in jail
Date: Thu, 25 Jul 2019 14:02:06 +0000
This is an example of what I was referring to.
https://www.cnbc.com/2019/07/24/jeffrey-epstein-injured-in-federal-jail-in-manhatan.html
Sent from my iPhone
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=== Page 1 ===
10f
3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
VIRGINIA L. GIUFFRE,
Plaintiff,
V.
15-cv-07433-LAP
GHISLAINE MAXWELL,
Defendant.
X
Ms. Maxwell's Objections to Unsealing Docket Entries 143, 173, and 199 and to
Unsealing Docket Entries 164 and 230 at This Time.
Laura A. Menninger
Jeffrey S. Pagliuca
Ty Gee
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.831.7364
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20f
3
Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order
and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the
unsealing of the Sealed Items contained in:
DE 143 (and related DEs 142, 144, 144-1, 149, 150, 150-1, 151, 152, 153, and 153-
1);
DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211,
212, 212-1, and 224) and;
DE 199 (and related DEs 200, 200-1, 228,2 29, 229-1, 284, 249, and 249-1).
The reasons for her objections are stated in her accompanying memorandum of law.
Ms. Maxwell, does not object to the potential unsealing of the Sealed Items contained in
DEs 164 and related DEs 165, 165-8, 185-3, 185-11, 185-14, 185-15 or DE 230 and related DEs
235, 235-5, 235-7, 235-11, 235-13 at a future date. However, unsealing of these Sealed Items
would be premature at this time because multiple Non-Party Does are referenced in these items,
as described in the accompanying memorandum of law, and should be provided Notice and an
opportunity to object pursuant to the Protocol.
Dated: June 10, 2020.
Respectfully submitted,
/s/Jeffrey S. Pagliuca
Laura A. Menninger (LM-1374)
Jeffrey S. Pagliuca (pro hac vice)
Ty Gee (pro hac vice)
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
lmenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
1
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30f
3
CERTIFICATE OF SERVICE
I certify that on June 10, 2020, I electronically served this Ms. Maxwell's Objections to
Unsealing Docket Entries 143, 173, and 199 and to Unsealing Docket Entries 164 and 230 at
This Time. via ECF on the following:
Sigrid S. McCawley
Paul G. Cassell
Meredith Schultz
383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP
Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200
cassellp@law.utah.edu
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
Andrew G. Celli
Bradley J. Edwards
David Lebowitz
Stan J. Pottinger
Emery Celli Brinckerhoff & Abady LLP
EDWARDS POTTINGER LLC
600 Fifth Avenue at Rockefeller Center
425 North Andrews Ave., Ste. 2
10th Floor
Ft. Lauderdale, FL 33301
New York, NY 10020
brad@pathtojustice.com
acelli@ecbalaw.com
StanPottinger@aol.com
dlebowitz@ecbalaw.com
Christine N. Walz
Jay M. Wolman
HOLLAND & KNIGHT LLP
Marc J. Randazza
31 West 52nd Street
RANDAZZA LEGAL GROUP, PLLC
New York, NY 10019
100 Pearl Street, 14th Floor
Christine.walz@hklaw.com
Hartford, CT 06103
jmw@randazza.com
mjr@randazza.com
/s/ Nicole Simmons
Nicole Simmons
2
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Case
1057
Filed 06/10/20
Page
17
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
VIRGINIA L. GIUFFRE,
Plaintiff,
V.
15-cv-07433-LAP
GHISLAINE MAXWELL,
Defendant.
X
Ms. Maxwell's Memorandum Brief In Support Of Her
Objections to Unsealing Sealed Materials
Laura A. Menninger
Jeffrey S. Pagliuca
Ty Gee
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.831.7364
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17
Pursuant to this Court's Order and protocol for Unsealing Decided Motions, Defendant
Ghislaine Maxwell, through her counsel objects to the unsealing of documents for the reasons
stated.
I. Overview
Docket Entries ("DE[s]") 143, 164, 172, 199, and 230 ("Sealed Material[s]" or "Sealed
Item[s]") have been selected by the Court, with respect to Does 1 and 2, to begin the process of
individualized review of these selected Sealed Materials to determine (a) the weight of
presumption of public access that should be afforded to an item, (b) the identification and weight
of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether
the countervailing interests rebut the presumption of public access to the item. Giuffre V. Maxwell,
No. 15-CV-07433-LAP, 2020 WL 1547377, at *1 (S.D.N.Y. Mar. 31, 2020); DE 1044. I Based on
the Court's clarification of its March 31, 2020 Order, DE 1053, ("the Protocol"), Non-Parties
Does 1 and 2 have been served with the approved Notice and, pursuant to the Protocol, additional
Non-Parties will be notified prior to any unsealing of the selected Sealed Materials.
Does 1 and 2 did not respond to the Notice. The absence of a response, however, does not
end the analysis. Although the Court's Protocol requires consideration of objections from the
other Non-Parties yet to be noticed, the Court could (and should) determine, based on the
circumstances of the Sealed Materials selected here, that the items are appropriately sealed
without the need for additional Non-Party objections.
I Pursuant to paragraph 2.g of the Order "any memorandum in support of a Party
Objection to unsealing a particular Sealed Item shall be no longer than 6 double-spaced pages in
12 point, Times New Roman Font. Ms. Maxwell has lodged objections to the identified
documents in 14 pages in compliance with the Order, i.e., this pledge is one-half of the authorized
length.
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Applying the three-part analysis set forth by the Court in its March 31, 2020 Order to the
selected Sealed Materials in Des 143, 172, and 199² results in a determination that: (a) the
selected Sealed Materials relate solely to five-year-old discovery disputes and therefore, at most,
begin with a presumption of public access "somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for
dismissal or summary judgment." Brown V. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (citing
United States V. Amodeo, 71 F.3d 1044, 1049-50 (2d Cir. 1995) ("Amodeo II")); (b) any minimum
presumption of public access is subject to many countervailing interests supporting continued
sealing; and (c) the countervailing interests rebut any minimal presumption of public access.
II. DE 143 and Related DEs 142, 144, 144-1-7, 149, 150, 150-1, 151, 152, 153, and 153-1
are afforded the lowest presumption of public access and these Sealed Materials
should remain sealed.
This series of pleadings concerns Plaintiff's attempt to compel Ms. Maxwell to answer
intrusive questions about her sex life. 34 DE 143 quotes extensively, selectively, and misleadingly
from Ms. Maxwell's first seven-hour deposition. DE 144-1-7 contains 7 exhibits: 1, 2, and 4-7 are
2 As discussed in Sections VII at VIII, infra, consideration of DEs 164 and 230 is
premature at this time.
3 DE 142 is a letter notice; DE 143 is the initial motion; DE 144 is a lawyer
declaration referencing the exhibits in DE 144-1-7. The declarations accompanying the
various Sealed Materials often identify a Non-Party. The Court may wish to simply redact
all of the Non-Party names from the declarations as a means of streamlining review and
Notice problems. DE 149 is Defendant's Response, 150 is a lawyer declaration
referencing the exhibit in DE 150-1. DE 151 is another letter notice. DE 152 is Plaintiff's
Reply. DE 153 is another lawyer declaration referencing the exhibits in DE 153-1-7. The
name of Doe 1 appears in DEs 152, p. 6 and 153 p. 2 II 7 and 8. Doe 2 does not appear in
any DE 143 related pleading.
4 The following DEs contain references to Non-Parties: DE 143 references 2 non-parties;
DE 144-1-7 references 7 non-parties; DE 150-1 references 9 non-parties.
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excerpts from Ms. Maxwell's deposition. Exhibit 3 contains pages from the Palm Beach Police
Report. DE 149 is Ms. Maxwell's response to DE 143.
Page 2 of DE 149 contains a summary of Ms. Maxwell's deposition testimony. DE 150-1
contains pages of Ms. Maxwell's deposition necessary to place Plaintiff's submission into
context. DE 153 is Plaintiff's reply which, again quotes from Ms. Maxwell's deposition and
references numerous Non-Parties. DE 153-1 contains 7 exhibits. Exhibit 1 is a portion of Ms.
Maxwell's deposition. Exhibit 2 contains a "Flight Log Summary Chart" prepared by Plaintiff's
counsel and flight logs that contain the names of numerous Non-Party Does. Exhibit 3 purports to
be 88 pages of Palm Beach Police Reports, some redacted, some unredacted, with multiple
references to Non-Party Does. Exhibit 4 and 7 are inadmissible hearsay transcripts from an
unreliable deceased individual never deposed by Ms. Maxwell. Exhibits 5 and 6 concern J. Doe 1.
III. DE 143, DE 144-1, exhibits 1, 2, and 4-7; DE 149, page 2, summary of Ms. Maxwell's
deposition testimony; DE 150-1; DE 153; and DE 153-1: Identification of
Countervailing Interests.
A. Countervailing Interests.
All of the above DEs are either quotes from, summaries of, or portions of transcripts from
Ms. Maxwell's deposition in this case. The subject matter of these DEs is extremely personal,
confidential, and subject to considerable abuse by the media. Countervailing interests include:
1. Reasonable reliance on a protective order by a party or non-party ("CI-1").
If a party or nonparty provides information in connection with a lawsuit in reasonable reliance
upon a Federal Rule of Civil Procedure 26(c) protective order, the information must remain
sealed. See Martindell V. Int'l Tel. & Tel. Corp., 594 F.2d 291, 296 (2d Cir. 1979); see id. at 297-
98 (Medina, J., concurring) (noting "overriding policy in favor of enforcing the civil protective
order against federal prosecutor's request for deposition transcripts", and holding "[A] plaintiff in
a civil litigation is bound by the terms of an agreement he has made to restrict the access of non-
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parties, including the Government, to the products of discovery. This was the essence of Judge
Frankel's decision in GAF Corp. V. Eastman Kodak Co., 415 F.Supp. 129 (S.D.N.Y.1976), with
which I fully concur.") (footnote omitted). Martindell was cited with approval in SEC V.
TheStreet.com, 273 F.3d 222, 232 (2d Cir. 2001), which was cited with approval in Brown, 929
F.3d at 51 n.40. Notably the Second Circuit in Brown held that redactions of sensitive, private
information disclosed by witnesses in depositions because of "a strong expectation of continued
confidentiality, Brown, 929 F.3d at 48 n.22, and the Second Circuit itself redacted sensitive
personal references in Ms. Maxwell's deposition testimony excerpts.
Ms. Maxwell was the Defendant in this defamation action. She did not inject her personal
life into this case and was deposed under a court-ordered guarantee that her testimony would
remain confidential. She relied on that order and has a strong expectation of continued
confidentiality.
2. Prevention of the abuse of court records and files ("CI-2").
Courts must exercise their supervisory power over their own records and files to ensure
they "are not used to gratify private spite or promote public scandal" or "serve as reservoirs of
libelous statements for press consumption." Brown, 929 F.3d at 51 (quoting Nixon V. Warner
Commc'ns, Inc., 435 U.S. 589, 598 (1978)). The Brown court held: "District courts should
exercise the full range of their substantial powers to ensure their files do not become vehicles for
defamation. Id. at 53. The above DE's are textbook examples of materials that should not be
submitted to courts because of their potential for abuse.
3. Annoyance, embarrassment, oppression, undue burden ("CI-3").
Materials that cause annoyance, embarrassment, oppression or undue burden to an
individual should be sealed or redacted. See Brown, 929 F.3d at 51. The questions were intrusive
and embarrassing.
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17
4. Preserving the fundamental rights of suspects or others under criminal
investigation ("CI-4").
The preservation of the fundamental rights of suspects and others under criminal
investigation is a powerful countervailing interest weighing against the presumption of access.
See Nixon, 435 U.S. at 595, 602; Brown, 929 F.3d at 47 n.13; Martindell, 594 F.2d at 295-97. The
courts have an obligation to safeguard the integrity of criminal investigations and the privacy and
safety of witnesses and suspects that are part of those investigations. United States V. Longueuil,
567 F. App'x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested
documents "as they reflected sensitive information about cooperating witnesses, "and concluding
that sealing was justified in part "to safeguard the privacy of individuals involved in an
investigation"; "[t]he district court was in the best position to weigh these factors") (internal
quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts
have found that the following can defeat presumption of access: protection of ongoing
investigations, safety of witnesses, national security, and trade secrets).
Ms. Maxwell is aware, based on publicly reported statements by Plaintiff, Plaintiff's
counsel, the United States Attorney for the Southern District of New York, and the Attorney
General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr.
Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These
ongoing investigations are a powerful countervailing interest here. The sealed testimony or
summaries may inappropriately influence potential witnesses or alleged victims.
IV. DE 144-1- Exhibit 3 (police reports); DE 153; DE 153- Exhibit 2 "Flight Log
Summary Chart" prepared by Plaintiff's counsel and flight logs; Exhibit 3 (88 pages
of police reports): Identification of Countervailing Interests.
Numerous yet to be notified Non-Party Does are mentioned in these documents and it is
premature for the Court to make any decision to unseal these documents prior to Notice.
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17
However, these materials are subject to the following countervailing interests regardless of
additional Non-Party objections:
A. Countervailing Interests
1. Prevention of the abuse of court records and files (CI-2).
Brown, 929 F.3d at 51and 53, see section III.A.2, supra.
2. Improper submission of documents ("CI-5").
Documents that a party has submitted for a non-merits purpose, e.g., the confidentiality,
discoverability or admissibility of information, should remain sealed or redacted if there is any
interest in sealing or redaction. See TheSreet. 273 F.3d at 233. The references to the various
attached exhibits were gratuitous and served no legitimate purpose related to the discovery
dispute. During the course of this litigation Plaintiff offered, on more than one occasion, various
iterations and compilations of the Palm Beach Police Reports in which no one identified Ms.
Maxwell as a suspect, a perpetrator, or participant. The attachment of alleged summaries of flight
logs, alleged flight logs, and police reports was simply a mechanism to attempt to bias the Court
and any potential future reader of the material. These issues were briefed in various undecided
motions in limine.
3. Untrustworthy, unreliable, and incorrect information ("CI-6").
Courts should continue the sealing or redaction of information that is or may be
untrustworthy, hearsay or incorrect or that simply is misinformation. United States V. Amodeo, 71
F.3d 1044, 1052 (2d Cir. 1995) ("Amedeo II") ("The nature of some parts of the Report militate
against unsealing, however. Portions of the Report are hearsay, and may contain misinformation.
There is a strong possibility that the report will contain material which is untrustworthy or simply
incorrect.") (internal quotations, brackets, citation and ellipsis omitted). Exhibits 4 and 7 are
inadmissible hearsay transcripts from an unreliable deceased individual never deposed by Ms.
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Maxwell. The exhibits could not be considered evidence and should not have been submitted to
the Court. The declarant suffered multiple felony convictions and had been involved in attempting
to obtain money from one of Plaintiff's lawyers in exchange for alleged evidence. These issues
were briefed in various undecided motions in limine.
V. DE 153-1 exhibits 4 and 7 and DE 153-1, exhibits 5 and 6: Identification of
Countervailing Interests
A. Countervailing Interests
1. Untrustworthy, unreliable, and incorrect information (CI-6).
Exhibits 5 and 6 concern J. Doe 1. Both exhibits are hearsay statements made by J. Doe 1
in proceedings that did not involve Ms. Maxwell. J. Doe 1 was not examined by Ms. Maxwell's
counsel in that proceeding making the statements unreliable and inadmissible.
VI. DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212,
212-1, and 224) are afforded the lowest presumption of public access and this Sealed
Material should remain sealed.
These pleadings concern what should have been a straightforward request by Plaintiff to
exceed the presumptive 10 deposition limit set by the Court.5 It was not. Instead of simply asking
to exceed the presumptive limit, Plaintiff felt the urge to pack the record with deposition
testimony subject to the Protective Order and references to multiple Non-Party Does including
deposition testimony from Non-Party Does.
5 DE 171 is a letter notice; DE 172 is the initial motion; DE 173 is a lawyer declaration
referencing the exhibits in DE 173-1. DE 189 is Defendant's Response, 190 is a lawyer
declaration referencing the exhibit in DE 190-1. DE 202 is another letter notice. DE 203 is
Plaintiff's Reply. DE 204 is another lawyer declaration referencing the exhibits in DE 204-1.
DEs 211, 212, 212, 212-1 and 224 are amended/corrected versions of DEs 202, 203, and 204-1.
The name of Doe 1 appears in DEs 172, pp. i, 2, 6, 11, and 12; 173 p. 2 II 5 and 10; 173-6 pp. 71,
73, and 218; 189 p. 6; 203, pp. 2, and 5-6, 204, p. 1 I 5; 204-3, all; 211, see 203; 212, see 204;
212-3, see 204-1:3; 224, see 203. Doe 2 appears in DEs 172, pp. i, 2, and 12; and 189 p.5.
The following DEs contain references to Non-Parties: DE 172 references 14 non-parties;
DE 173-1 references 47 non-parties; DE 189 references 8 non-parties; DE 203 references 12 non-
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Given the repeated references to Non-Parties it is premature for the Court to make any
decision to unseal these documents prior to Notice. However, Countervailing interests exist that
warrant a decision to seal many of the Selected Materials regardless of any additional Non-Party
objections.
A. Identification of Countervailing Interests
1. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4).
DE 172 contains multiple references to Ms. Maxwell's deposition testimony and the
deposition testimony of one other Non-Party taken pursuant to the Protective Order. See pp. 2, 4-8
as to Ms. Maxwell and pp. 3, 4, 9, and 11 as to an additional Non-Party Doe. Reasonable reliance
on a protective order by a party or non-party, Prevention of the abuse of court records and files,
Annoyance, embarrassment, oppression, undue burden, Preserving the fundamental rights of
suspects or others under criminal investigation, all identified in section III.A.1-4 apply to these
pages of DE 172.
2. Non-Judicial Documents ("CI-7").
In defining "judicial records and documents," the Second Circuit "ha[s] emphasized that
'the mere filing of a paper or document with the court is insufficient to render that paper a judicial
document subject to the right of public access." Brown V. Maxwell, 929 F.3d 41, 49 (2d Cir.
2019) (emphasis supplied; footnote omitted; quoting United States V. Amodeo, 44 F.3d 141, 145
(2d Cir. 1995) ("Amodeo r')). Amodeo I, the inception of the Second Circuit's principle that a file
stamp is not a judicial-document talisman, is instructive. There an appointed Court Officer tasked
parties; DE 204-1 references 4 non-parties; DE 211 references 12 non-parties; DE 202 references
2 non-parties; DE 202-1 references 2 non-parties; DE 224 references 8 non-parties.
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with an investigation for the District Court for the Southern District of New York prepared and
filed with the court a sealed report of her investigation. Newsday moved to unseal the report.
After the court released an edited and redacted copy of the report, Newsday appealed. See 44 F.3d
at 142-43.
If its mere filing transformed the report into a judicial document, Amodeo I would have
been categorical and succinct. It was neither. The decision turned on the Second Circuit's lengthy
discussion of the First and Third Circuits' divergent approaches to the question, when is a mere
document transformed into a judicial one? The Third Circuit's focus was "on the technical
question of whether a document is physically on file with the court." Amodeo I, 44 F.3d at 145
(quoting Pansy V. Borough of Stroudsburg, 23 F.3d 772, 782 (3d Cir. 1994)). In that circuit if a
document is filed with a court, it is a judicial document; otherwise it is not. See id. (citing Pansy,
23 F.3d at 782). The Amodeo I court cited two other Third Circuit cases confirming that circuit's
litmus-test approach to identifying judicial documents: Bank of America National Trust and
Savings Association V. Hotel Rittenhouse Association, 800 F.2d 339, 344-45 (3d Cir. 1986)
("Once a settlement is filed in the district court, it becomes a judicial record, and subject to the
access accorded such records."); Leucadia, Inc. V. Applied Extrusion Technologies, Inc., 998 F.2d
157, 161-62 (3d Cir. 1993) (listing cases in which "other courts have also recognized the principle
that the filing of a document gives rise to a presumptive right of public access"). Amodeo I, 44
F.3d at 145.
The First Circuit "has taken a somewhat different approach," id. In that circuit "documents
must have a role in the adjudication process in order to be accessible and documents that have
no such role, such as those used in discovery, cannot be reached." Id. (citing Anderson V.
Cryovac, Inc., 805 F.2d 1, 13 (1st Cir. 1986)). Amodeo I found instructive F.T.C. V. Standard
9
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Financial Management Corp., 830 F.2d 404 (1st Cir. 1987). In F.T.C. a district court relied upon
financial records referenced in a proposed consent decree in deciding whether to approve the
decree. The First Circuit held the financial records were judicial documents because they were
submitted to the court as part of the decree-approval process, they were "relevant and material"
to the process, and the district court "relied upon the documents in assessing the reasonableness of
the order, i.e., in determining the litigants' substantive rights, and in performing its adjudicatory
function." Id. (quoting F.T.C., 830 F.2d at 410).
The Second Circuit adopted the First Circuit's approach:
We think that the mere filing of a paper or document with the court is insufficient
to render that paper a judicial document subject to the right of public access. We
think that the item filed must be relevant to the performance of the judicial
function and useful in the judicial process in order for it to be designated a judicial
document.
Id. Brown was building on Amodeo I's holding when it said, "As our precedent makes clear, a
court "perform[s] the judicial function' when it rules on motions currently before it." Brown,
929 F.3d at 49 (emphasis supplied; footnote omitted; quoting Amodeo I, 44 F.3d at 145). And it
was building on Amodeo I when it said, "A document is thus 'relevant to the performance of the
judicial function' if it would reasonably have the tendency to influence a district court's ruling on
a motion
Id. (emphasis supplied; footnote omitted; quoting Amodeo I, 44 F.3d at 145). Both
Brown accretions to the Amodeo I principle are themselves dependent upon the principle. If a
motion is not "currently before" the district court, then a fortiori the court is not "perform[ing] the
judicial function." And if a motion is not currently before the court, then a fortiori it cannot
"reasonably have [a] tendency to influence" the court.
Brown's holding was hardly a surprise. It followed S.E.C. V. TheStreet. Com, 273 F.3d 222,
233 (2d Cir. 2001). There the Second Circuit held that documents that "did not "directly affect an
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adjudication' nor significantly 'determine litigants' substantive rights" were not judicial
documents. (Brackets omitted; quoting United States V. Amodeo, 71 F.3d 1044, 1049 (2d Cir.
1995) ("Amodeo II").)
DE 173, a declaration, references additional Non-Parties, generally those identified in
lawyer emails. The Court may wish to defer consideration of this DE. Redaction of the names
would eliminate any issue related to this document. DE 173-1 exhibits 1-4 identify additional
Non-Parties. Generally, these exhibits are a composite of various back and forth emails between
counsel which are hearsay, non-judicial, documents and which contain the identity of Non-Party
Does. This exhibit should not be considered a judicial document. The arguments of counsel in
self-serving emails are generally not reliable evidence upon which any judicial decision rests or
should rest.
3. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4).
Untrustworthy, unreliable, and incorrect information (CI-6).
DE 172-1, exhibit 5, is an entire, 160-page, Non-Party deposition taken under the
guarantee of the Protective Order entered in this case and should be sealed by application of the
countervailing interests identified in [] above. Similarly DE 172-1, exhibit 6 is the entire, 418-
page, deposition of Ms. Maxwell taken under the guarantee of the Protective Order and should
remain sealed based on the countervailing interests identified above.
DE 172-1, exhibit 7, is yet another copy of the same 88 pages of police reports attached to
many other pleadings in this case. This exhibit should remain sealed for the reasons discussed in
section VI.A.2 and 3, supra.
DE 172-1, exhibit 8, is an identical copy of J. Doe 1's hearsay statement attached to DE
153-1 and should be sealed for the same reasons discussed in section V.A.1.
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4. Non-Judicial Documents (CI-7)
DE 172-1, exhibit 9, is additional counsel generated, self-serving correspondence that is
not a judicial document as discussed in section VI.A.2 above.
5. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4).
DE 189 is Defendant's response to the motion. Page 5 of the response contains a
paragraph quoting the deposition testimony of a Non-Party taken pursuant to the Protective Order
which should remain sealed because of countervailing factors CI-1 through CI-4. The remaining
portions of that document can be unsealed, subject to any additional Non-Party objections.
DE 190 and 190-1 relate to deposition testimony by Plaintiff. Ms. Maxwell has no
objection to unsealing these documents, subject to any Non-Party objections.
6. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4).
DE 203, Plaintiff's reply, contains numerous quotes from the protected deposition
testimony taken from Non-Party Does and should remain sealed based on countervailing interests
discussed above.
7. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4).
DE 204 and 204-1 relate to the deposition testimony of three Non-Party Does including J.
Doe 1. All of the references to the Non-Parties and the testimony should remain sealed based on
the countervailing interests discussed above. Exhibit 1 to DE 204 is the testimony of a J. Doe, yet
to receive Notice, taken subject to the Protective Order which was relied on by the J. Doe. Exhibit
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2 to DE 204-1 is a "rough" transcript of a yet to be notice J. Doe also taken pursuant to the
Protective Order. Exhibit 3 to DE 204-1 is deposition testimony taken of J. Doe 1 pursuant to the
Protective Order. Although J. Doe 1 has not responded to the notice, J. Doe 1 made it clear in this
deposition that J. Doe 1 did not want any further involvement in this matter and that J. Doe 1 was
unable to accurately recall details of the events described as a result of a medical condition. DEs
211, 212, and 212-1 are the same as DEs 203, 201 and 204-1 and should be treated identically.
VII. DE 199 (and related DEs 200, 200-1, 228, 229, 229-1, 248, 249, and 249-1) are
afforded the lowest presumption of public access and this Sealed Material should
remain sealed.
1. Reasonable reliance on a protective order by a party or non-party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under criminal investigation (CI-4)
and Redactions of Names.
These pleadings relate to Plaintiff's request for additional time to complete the depositions
referenced in her pleadings related to her request for more depositions. Generally, the DEs
reference Non-Party Does and refer in some instances to Non-Party deposition testimony taken
under the guarantees of the Protective Order. The Court, prior to unsealing the Sealed Materials,
will require the responses of yet to be notified Non-Party Does.⁷ However, it appears that the
volume of Sealed Material in these DEs is minimal. The Court could determine that the Sealed
Materials remain sealed by application of countervailing interests CI-1 through CI-4.
7 The following DEs contain references to Non-Parties: DE 228 references 14 non-parties;
DE 229 references 5 non-parties; DE 229-1 references 33 non-parties; DE 248 references 17 non-
parties; DE 249 references 9 non-parties; DE 249-1 references 18 non-parties.
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VIII. DE 164 (and related DEs 165, 165-8, 185-3, 185-11, 185-14, 185-15). Should Remain
Sealed Pending Additional Non-Party Notice and Responses Pursuant to The
Protocol.
The pleadings related to DE 164 concern discovery related to a waiver of Plaintiff's
attorney client privilege as a result of her lawyers' extrajudicial conduct and statements and
Plaintiff's statements in other matters.8 Accordingly, these materials are afforded the lowest
presumption of public access. However, Ms. Maxwell anticipates that, subject to any objections
from, yet-to-be-noticed, Non-Party Does she has no objection to the release of these materials.
Release at this time is premature, because various Non-Parties may raise countervailing interests
that must be addressed by the Court pursuant to the Protocol.9
IX. DE 230 and (and related DEs 235, 235-5, 235-7, 235-11, 235-13). Should Remain
Sealed Pending Additional Non-Party Notice and Responses Pursuant to The
Protocol.
The Pleadings related to DE 230 concern the reopening of Plaintiff's deposition.
Accordingly, these materials are afforded the lowest presumption of public access¹⁰. However,
Ms. Maxwell anticipates that, subject to any objections from, yet-to-be-noticed, Non-Party Does
she has no objection to the release of these materials. Release at this time is premature, because
8 DE 165 is a lawyer declaration referencing the exhibit DE165-8; DE 185-3 is a Response
to Motion to Intervene; DE 185-11 are pgs. from Plaintiff's deposition; DE 185-14 are pages from
one of Plaintiff's lawyers' deposition; DE 185-15 is an interview between Plaintiff and two of her
lawyers.
9 The following DEs contain references to Non-Parties: DE 165 references 1 non-party;
DE 165-8 references 1 non-party; DE 185-3 references 12 non-parties; DE 185-11 references 8
non-parties; DE 185-14 references 1 non-party; DE 185-15 references 15 non-parties.
10 DE 235 is a redacted lawyer declaration referencing a non-party and exhibits DE 235-5,
235-7, 235-11, 235-13.; DE 235-5 contains letters between counsel; 235-7 is an expert from a
non-party deposition, 235-11 is a privilege log; 235-13 is an errata sheet from a deposition.
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various Non-Parties may raise countervailing interests that must be addressed by the Court
pursuant to the Protocol. 11
X. Conclusion
Substantial interests warrant a continued finding by the Court that the various Sealed
Documents at issue here remained sealed.
Dated: June 10, 2020.
Respectfully submitted,
/s/Jeffrey S. Pagliuca
Laura A. Menninger (LM-1374)
Jeffrey S. Pagliuca (pro hac vice)
Ty Gee (pro hac vice)
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
lmenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
11 The following DEs contain references to Non-Parties: DE 235 references 1 non-party,
DE 235-5 references 3 non-parties; DE 235-7 references 1 non-party; DE 235-11 references 3
non-parties; DE 235-13 references 3 non-parties.
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CERTIFICATE OF SERVICE
I certify that on June 10, 2020, I electronically served this Ms. Maxwell's Memorandum Brief In
Support of Her Objections to Unsealing Sealed Materials via ECF on the following:
Sigrid S. McCawley
Paul G. Cassell
Meredith Schultz
383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP
Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200
cassellp@law.utah.edu
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
Andrew G. Celli
Bradley J. Edwards
David Lebowitz
Stan J. Pottinger
Emery Celli Brinckerhoff & Abady LLP
EDWARDS POTTINGER LLC
600 Fifth Avenue at Rockefeller Center
425 North Andrews Ave., Ste. 2
10th Floor
Ft. Lauderdale, FL 33301
New York, NY 10020
brad@pathtojustice.com
acelli@ecbalaw.com
StanPottinger@aol.com
dlebowitz@ecbalaw.com
Christine N. Walz
Jay M. Wolman
HOLLAND & KNIGHT LLP
Marc J. Randazza
31 West 52nd Street
RANDAZZA LEGAL GROUP, PLLC
New York, NY 10019
100 Pearl Street, 14th Floor
Christine.walz@hklaw.com
Hartford, CT 06103
jmw@randazza.com
mjr@randazza.com
/s/ Nicole Simmons
Nicole Simmons
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