# docs_fts_content

c1: EFTA00031372
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031372.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
Subject: RE: New Investigation
Date: Thu, 06 Dec 2018 23:09:37 +0000
Importance: Normal
No worries, happy to talk any time.
Original Message
From:
,
(USANYS)
Sent: Thursday, December 6, 2018 6:04 PM
To:
)
Cc:
)
Subject: Re: New Investigation
Sorry I missed this. I am super annoyed. Just got out of mag court. Running home to feed the baby. But I am
around later tonight or tomorrow afternoon when I come back from white plains.
Sent from my iPhone
> On Dec 6, 2018, at 5:46 PM,
)
wrote:
>
> Thanks for taking the time to meet today-attached are the documents we mentioned.
>
> From:
,
(NY) (FBI)
> Sent: Thursday, December 6, 2018 1:40 PM
> To:
i
)
> Cc:
)
;
(USANYS)
> Subject: Re: New Investigation
>
>
I am still in NJ. I have everything we have downloaded to CD. It's at the office. I can bring it when we meet.
V
>
>
V
>
>
V
Original message
> From:
:
,
> Date: 12/6/18 1:38 PM (GMT-05:00)
> To:
)"
<mailto:
> Cc:
)"
<mailto:
(USANYS)"
<mailto:
.
(NY) (FBI)"
<mailto:
V
Subject: Re: New Investigation
V
> I'm in the proffer and do not have the disc with me. If I'm not mistaken
may still be in NJ. If I finish up
over here earlier then expected I'll ran back and grab it.
EFTA00031372

=== Page 2 ===
V
>
On Dec 6, 2018, at 12:59,
<mailto:
wrote:
> Hi all-looking forward to meeting this afternoon. If you're able to bring over a copy of the files on this case
(we'll take as much stuff as possible!), we'd really appreciate it. CD or drive are both fine.
>
> Thanks!
V
> From:
)
<mailto:
> Sent: Tuesday, December 4, 2018 7:19 PM
> To:
(USANYS)
<mailto:
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: RE: New Investigation
>
> No worries at all, and I'll make 4:30 work.
>
>
> From:
,
> Sent: Tuesday, December 04, 2018 19:16
> To:
)
<mailto:
(USANYS)
<mailto:
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
>
>
> I have child care issues in the mornings typically, and getting in by 11:00 is often difficult as I live in Suffolk
County. 4:30 works better for me. Sorry about that!
V
V
>
> Detective
V
> NYPD / FBI
V
V
Child Exploitation Human Trafficking Task Force
V
V
V V V V V V
From:
)
<mailto:
Sent: Tuesday, December 4, 2018 7:06:28 PM
> To:
(USANYS);
(NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
EFTA00031373

=== Page 3 ===
> I unfortunately have calls at 4:00 and 4:30. Could we do earlier before 11:00? I'm also concerned that if the
proffer ends up going late we'll be out of luck. Or I can move the 4:30 if
preferable for everybody. Sorry
about that.
V
V
V
V
V
> From:
> Sent: Tuesday, December 04, 2018 19:04
> To:
)
<mailto:
(USANYS)
<mailto:
>;
(NY) (FBI)
<mailto:
> Cc:
)
<mailto:
> Subject: Re: New Investigation
>
>
>
> 11:00 will not work for me. Me and
are good for 4:00 on Thursday though. The proffer should be done
by then.
V
V
>
> Detective
V
> NYPD / FBI
V
>
Child Exploitation Human Trafficking Task Force
V
V
> From:
)
V V V V V V V V V V A V V V
<mailto:
Sent: Tuesday, December 4, 2018 6:34:53 PM
> To:
;
,
(USANYS);
(NY) (FBI)
> Cc:
)
> Subject: RE: New Investigation
Let's do Thursday, particularly since schedules seem to be tough next week.
would it make sense to meet
-
before your proffer, so we can have a specified time? We could meet at 11:00.
> thanks,
EFTA00031374

=== Page 4 ===
V
V
V
> From:
,
> Sent: Tuesday, December 04, 2018 15:54
> To:
(USANYS)
<mailto:
>;
,
(NY) (FBI)
<mailto:
> Cc:
<mailto:
)
<mailto:
> Subject: Re: New Investigation
V
V
V
> Hey guys,
V
>
>
> Thursday I have a proffer at SNDY with SA
at 12:00. I can meet after that if you guys want depending
on how long this proffer goes. That may be the best option for us because Monday-Wednesday of next week we
may be tied up with a take down in the office.
>
>
V
> Detective
>
> NYPD / FBI
>
> Child Exploitation Human Trafficking Task Force
V
V
> From:
(USANYS)
<mailto:
,
V V V V V V V V V V V V V
> Sent: Tuesday, December 4, 2018 3:30:14 PM
> To:
(NY) (FBI);
> Cc:
);
)
> Subject: RE: New Investigation
> Thursday works for me.
Next week I am good Monday-Tuesday and Thursday-Friday.
> From:
(NY) (FBI)
<mailto:
,
EFTA00031375

=== Page 5 ===
> Sent: Tuesday, December 04, 2018 3:23 PM
> To:
(USANYS)
<mailto:
(
> Cc:
<mailto:
)
<mailto:
> Subject: RE: New Investigation
> Hey
V V V V V V
> The only day I'd be free this week would be Thursday. Next Wednesday is not good, but any other day next
week I should be ok right now.
>
V
>
> I'm also working on putting everything we currently have onto a disk for you, so I should have that for you
when we meet.
>
>
V
> From:
(USANYS) [mailto:
> Sent: Tuesday, December 04, 2018 2:14 PM
> To:
(NY) (FBI)
<mailto:
,
W. (NY)
(OGA)
> Cc:
)
<mailto:
)
<mailto:
> Subject: RE: New Investigation
V
V
>
>
good speaking with you. I understand that you and
were just assigned the case yesterday and are
just starting to dig in. As we discussed I think it makes sense for us all to get into a room together son and chat.
V
V
V
> When works for you guys?
>
V
V
> From:
(USANYS)
> Sent: Monday, December 03, 2018 5:51 PM
> To:
(NY) (FBI)
<mailto:
,
>;
W. (NY)
(OGA) (FBI)
> Cc:
<mailto:
>;
)
<mailto:
> Subject: New Investigation
V
V
V
>
and
,
EFTA00031376

=== Page 6 ===
We got the package you dropped off today. Thank you. CC'ing the other members of the team on this email.
V V V V V V V V V V V V V V V V V V V V V V V V
> Best,
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
>
>
>
> <Palm Beach Police Reports.pdf>
> <Epstein Blackbook.pdf>
> <Flight Logs.pdf>
EFTA00031377


c1: EFTA00030625
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030625.pdf
c6: pdf
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: financial documents (Epstein)
Date: Tue, 23 Jul 2019 14:45:28 +0000
Is there an agenda for this? If so, I have no problem meeting in person, but if we just expect it to be like 10 minutes of
introducing ourselves then I'd personally vote phone call.
From:
Sent: Tuesday, July 23, 2019 10:45
To:
is
Subject: RE: financial documents (Epstein)
Same here, thanks. Would you guys prefer in person or by phone? I have no preference.
From:
Sent: Tuesday, July 23, 2019 10:41 AM
To:
V.
Subject: RE: financial documents (Epstein)
That works for me
From:
)
Sent: Tuesday, July 23, 2019 10:40
To:
is
Subject: RE: financial documents (Epstein)
1:30?
From:
Sent: Tuesday, July 23, 2019 10:31 AM
To:
>;
Subject: FW: financial documents (Epstein)
just called me to check in. Is there a time this afternoon that works for everyone? He's around.
From:
(NY) (FBI)
Sent: Thursday, July 18, 2019 7:33 PM
To:
is
V.
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Looking forward to working with you as well. My Tuesday is open. Set a time that works for you.
Best
EFTA00030625

=== Page 2 ===
From:
)
[mailto:
Sent: Thursday, July 18, 2019 6:58 PM
To:
is
is
(NY) (FBI)
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Hi
looking forward to working with you again! Aside from a court conference at 11 on Tuesday, I can make any
time work. Thanks.
From:
Sent: Thursday, July 18, 2019 6:56 PM
To:
is
(NY) (FBI)
is
(NY) (FBI)
Cc:
is
)
Subject: RE: financial documents (Epstein)
great to have you onboard, welcome - and as of now I don't have anything scheduled for Tuesday.
From:
Sent: Thursday, July 18, 2019 16:49
To:
)
[Contractor]
Cc:
is
(NY) (FBI)
is
is
is
(NY) (FBI)
Subject: Re: financial documents (Epstein)
I've CC'd the forensic accountant
in our squad who will be assisting in this investigation. Let's try and plan a
day next week to meet briefly and discuss a game plan. Are you guys around Tuesday to chat?
On Jul 18, 2019, at 11:17,
)
[Contractor]
wrote:
I have the discs, where should I bring them?
From:
)
Sent: Wednesday, July 17, 2019 8:47 PM
To:
)
[Contractor]
Cc:
(NY) (FBI)
is
is
)
is
;
Subject: RE: financial documents (Epstein)
Tomorrow morning could you please burn the following folders to a disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns American Express
EFTA00030626

=== Page 3 ===
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
at the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030627


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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030182.pdf
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=== Page 1 ===
From:
Subject: transition
Date: Wed, 10 Jul 2019 02:02:06 +0000
Importance: Normal
"Is the Epstein case going to cause a problem [for confirmation hearings]?" Acosta
had been asked. Acosta had explained, breezily, apparently, that back in the day he'd
had just one meeting on the Epstein case. He'd cut the non-prosecution deal with
one of Epstein's attorneys because he had "been told" to back off, that Epstein was
above his pay grade. "I was told Epstein 'belonged to intelligence' and to leave it
alone," he told his interviewers in the Trump transition, who evidently thought that
was a sufficient answer and went ahead and hired Acosta. (The Labor Department
had no comment when asked about this.)
https://www.thedailybeast.com/jeffrey-epsteins-sick-story-played-out-for-years-in-plain-sight
Assistant U.S. Attorney
Southern District of New York
EFTA00030182


c1: EFTA00031876
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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031876.pdf
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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:28:52 +0000
Inline-Images: image001.png
Thanks so much!!
From
Sent: Thursday, July 2, 2020 1:24 PM
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations! I'm very proud of you guys.
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 UNITED DONING SUBTOTAL
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
EFTA00031876

=== Page 2 ===
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00031877

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
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[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.
EFTA00031878


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=== Page 1 ===
From:
To:
Subject: Call with Osborn (Epstein)
Date: Thu, 31 Oct 2019 13:41:24 +0000
Importance: Normal
Attachments: unnamed
EFTA00031404


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=== Page 1 ===
From:
To:
Subject: RE: When is the Epstein presentment?
Date: Mon, 08 Jul 2019 16:56:24 +0000
Importance: Normal
Great, congratulations!
Original Message
From:
Sent: Monday, July 08, 2019 12:43 PM
To:
Subject: Re: When is the Epstein presentment?
They haven't called us down yet. It'll be in Portman's courtroom though- not 5A.
Sent from my iPhone
> On Jul 8, 2019, at 12:29 PM,
wrote:
>
>
>
> Sent from my iPhone
EFTA00030244


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=== Page 1 ===
From:
To:
Cc:
Subject: Discovery Production
Date: Fri, 21 Aug 2020 22:20:31 +0000
Attachments: 2020.08.21_Maxwell_Discovery_Letter.pdf
Counsel,
Attached please find a cover letter regarding today's production of discovery materials in US V. Maxwell. The password for
today's production is:
Best,
Assistant United States Attorney
Southern District of New York
EFTA00030991


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Bcc:
"
Subject: RE: Draft Statement
Date: Thu, 12 Nov 2020 22:32:41 +0000
Embedded: RE:_Draft_Statement_.msg
Sender:
Subject: RE: Draft Statement
Message-Id:
<CY1P110MB018442382B4182FF37EC1D4D8AE70@CY1P110MB0184.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00029964


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=== Page 1 ===
From:
)"
To:
,
)"
Subject: SW
Date: Sun, 07 Jul 2019 01:32:03 +0000
Importance: Normal
Attachments:
v2.docx
Attached is a quick (rough!) draft. I didn't really edit the rider, except to add a few bullet points as reminders, because I
am not sure what the scope of the search we are seeking is. Can you guys review and take a crack at it? FBI has asked us
to do this quickly, so if we could all focus on this for the moment, I'd really appreciate it. Thanks.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030818


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=== Page 1 ===
From:
Subject: Fwd: OPR Epstein Final Report
Date: Fri, 29 Jan 2021 22:29:15 +0000
Attachments: PR_458587-v1-Epstein_Report_transmittal_to_SDNY_(letter_signed).PDF; OPR-
_458557-v1-Epstein_Report_of_Investigation_and_Exhibits_pdf.PDF
Sent from my iPhone
Begin forwarded message:
From:
Date: November 12, 2020 at 10:06:50 AM EST
Subject: OPR Epstein Final Report
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
EFTA00029891


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=== Page 1 ===
From:
To:
Subject: indictment
Date: Wed, 04 Dec 2019 19:33:06 +0000
Attachments: Noel_and_Thomas_Indictment_v11.docx
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00030659


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=== Page 1 ===
From:
"
)"
To:
Bcc:
"
Subject: RE: OPR's Epstein Report.
Date: Mon, 01 Feb 2021 19:39:07 +0000
Embedded: RE:_OPR's_Epstein_Report.msg
Sender:
Subject: RE: OPR's Epstein Report.
Message-Id:
<BN3P110MB0276AC7A8E493F91D4681AA6A0B69@BN3P110MB0276.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00029840


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=== Page 1 ===
From: Marc Fernich
To:
)"
Cc: Marty Weinberg
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Tue, 09 Jul 2019 19:35:07 +0000
Thanks. I'll try that one too.
Marc Fernich, Esq.
Sent from my iPhone
On Jul 9, 2019, at 3:26 PM,
)
wrote:
Marc,
It is the right number, so feel free to follow up later, but I can also give you her cell number which is
thanks,
From: Marc Fernich
Sent: Tuesday, July 09, 2019 14:56
To:
Cc: Marty Weinberg
is
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Sorry to trouble again. No answer or VM pickup at that number. I'll try again later so long as it's the right number. Can
you confirm? Many thanks.
Marc Fernich, Esq.
EFTA00030238

=== Page 2 ===
Sent from my iPhone
On Jul 9, 2019, at 2:45 PM,
wrote:
Marc,
Apologies for the delay on this, and thanks for following up. The best way to coordinate this is to contact the case
agent directly - I just spoke to her so she'll be expecting your call. They're running around, so if you reach out and
aren't able to connect today please let me know, but hopefully we can get it coordinated. The contact is Special Agent
and she can be reached at
thanks,
From: Marc Fernich
Sent: Monday, July 08, 2019 15:40
To:
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
One of your agents told Marty the case agent would return Epstein's phone, the cash and other items taken from his
person upon arrest. Marty's returning to Boston shortly. Can you arrange for me to take possession of those items?
Thanks,
Marc
Marc Fernich, Esq.
Sent from my iPhone
On Jul 8, 2019, at 10:53 AM,
wrote:
Marc,
Wanted to send this to you as well in case your co-counsel can't receive it in the Court. Please let me know if it
would be helpful to get a hard copy - I'm copying two of our paralegals who can bring you (or co-counsel) a copy; l'll
be unreachable for the next hour or so.
thank you,
EFTA00030239

=== Page 3 ===
From:
Sent: Monday, July 08, 2019 10:43
To:
Cc:
is
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Pitman:
In advance of the expected bail argument in the above-captioned case, in connection with the presentment and
arraignment referred by Judge Berman, attached please find a memorandum from the government on the issue of
detention. Defense counsel is copied, as is the chambers of Judge Berman at their request.
Thank you,
Assistant U.S. Attorney
Southern Distri
<U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum.pdf>
EFTA00030240


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=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B7
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #:
None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From: (U//FOUO) DET
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
Holding Office: MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
SDNY_GM_02753575
EFTA00029918

=== Page 2 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B7
Barcode : E42292341
Accepted By
Printed Na
Reason: 0
Accepted By
Printed Na
Reason:
Accepted By
Printed Na
Reason:
Accepted By
Printed Na
Reason:
Accepted By
Printed Na
Reason:
Accepted By:
Printed Na
Reason:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Reason:
6/14/19 Signature:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753576
EFTA00029919

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinq
Date and
Time
Signature
Printed
c/18/19
Reason
2:35PM
Relinq
Date and
Time
Signature
Printed
6/18/19
Reason
3:45p
Relinq
Date and
Time
Signature
3/4/21
Printed
Reason
12:27pm
Relinqu
Date and
Time
Signature
3/31/21
Printed
Reason
3355p
Relinque
Date and
Time
Signature
Printed
4/8/21
Reason
233pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 7
Barcode: E4229234
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753577
EFTA00029920


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=== Page 1 ===
From:
To:
Subject: RE: I mean
Date: Fri, 08 Nov 2019 22:07:03 +0000
Really?
https://nypost.com/2019/11/08/epstein-didnt-kill-himself-printed-on-california-brewerys-beer-cans/
From:
Sent: Thursday, November 7, 2019 2:55 PM
To:
Subject: I mean
jesus.
https://nypost.com/2019/11/07/paging-epstein-coverup-airport-says-message-was-a-mistake/
Assistant U.S. Attorney
Southern District of New York
EFTA00030701


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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 18:13:28 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf, Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Congratulations!!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED 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
EFTA00031520

=== 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.
EFTA00031521

=== 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.
EFTA00031522


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: STAMPED NDO's & PEN's
Date: Mon, 15 Jun 2020 16:40:55 +0000
Attachments:
Hello,
Attached hereto are your NDO's & PEN's that were submitted to Mag Court which are now stamped and signed.
Thank you,
Legal Assistant - Criminal Clerk
United States Attorney's Office
Southern District of New York
EFTA00030360


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=== Page 1 ===
From
To
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 00:25:45 +0000
Thanks,
That means a lot.
From:
Sent: Sunday, November 28, 2021 3:04 PM
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
I LOVE this email. Even though I've only been involved tangentially as you all have moved mountains to get to
this point, I feel more invested than usual in the work you are doing. Please let me know if there is any help, no
matter what day or time it is, that I'm able to provide as the battle continues. Always remember that even
unlimited resources can't buy facts or truth.
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc
Subject: United States V. Ghislaine Maxwell
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031256


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=== Page 1 ===
Event: Call re: Epstein FOIA
Start Date: 2021-03-19 13:00:00 +0000
End Date: 2021-03-19 13:30:00 +0000
Organizer:
)
Location:
Class: X-PERSONAL
Date Created: 2021-03-11 21:44:49 +0000
Date Modified: 2021-03-11 21:44:49 +0000
Priority: 5
DTSTAMP: 2021-03-11 20:29:13 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00030077


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: United States V. Epstein
Date: Fri, 30 Aug 2019 20:07:11 +0000
Attachments: J8RpEPSf.pdf
We did -- attached.
thanks,
Original Message
From:
Sent: Thursday, August 29, 2019 23:24
To:
Cc:
Subject: United States V. Epstein
Hi
Did y'all order a transcript of this week's hearing? If not, will you point us in the right direction to order one?
Thanks!
EFTA00031309


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Epstein search warrant returns
Date: Tue, 20 Oct 2020 00:49:35 +0000
- so sorry, I didn't realize you'd already sent an STR report. Thanks!
From:
(USANYS)
Sent: Monday, October 19, 2020 8:46 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein search warrant returns
Hi
Hope you're doing well. Are you able to send us a report tomorrow summarizing the search terms you ran for the
responsiveness review in the Epstein search warrant database? We want to see which terms are pulling in the highest
volume of documents.
If at all possible, we'd really appreciate this tomorrow morning, as we're on a tight turnaround for finalizing our review.
Thanks so much-
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030549


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=== Page 1 ===
denial "). A properly instructed jury could conclude after hearing all of the evidence at trial
that the defendant intended the natural meaning of the words she used, not the allegedly truthful
answer she suggests now, and therefore that she lied. In sum, the defendant's post-hoc efforts to
inject confusion into clear questioning are unavailing and should be rejected, and the jury should
decide whether the defendant's answers were false.
2.
July 2016 Deposition
Count Six charges the defendant with perjury arising from three colloquies at the second
deposition. During the deposition, the defendant acknowledged that she had engaged in "sexual
activities" with persons "other than Mr. Epstein at Mr. Epstein's home in Palm Beach." (Ex. 11
at 54:24-55:5). Although she did not remember the names of any of those women, she recalled a
"blond" and a "brunette." (Id. at 56:22-57:18)
lawyer later inquired as to whether any
of those women were "professional masseuses" or whether any of them gave Epstein or the
defendant
"massages."
(Id.
at
85:21-86:12)
Following that line of questioning, the following
colloquy occurred:
Q. When you and Mr. Epstein were engaged in sexual activity that
included these other women, were any devices or sex toys used as
part of the sexual activity?
A. No
Q. Were you ever involved in sexual activities in Mr. Epstein's Palm
Beach house that included the use of sex toys or any kind of
mechanical or other device?
MR. PAGLIUCA: Objection to form and foundation
A. No
Q. Were you ever involved in sexual activities in any of Mr.
Epstein's properties other than Palm Beach that included the use of
sex toys or any kind of mechanical or other device?
129
EFTA00029847

=== Page 2 ===
A. No.
Q. Were you aware of the presence of sex toys or devices used in
sexual activities in Mr. Epstein's Palm Beach house?
MR. PAGLIUCA: Objection to form and foundation
A. No, not that I recall.
(Id. at 87:15-88:14)
After questions about Epstein's other properties,
lawyer asked the following
question:
Q. Do you know whether Mr. Epstein possessed sex toys or devices
used in sexual activities?
MR. PAGLIUCA: Objection to form and foundation
A. No.
(Id. at 89:8-13).
The defendant now argues that these questions are ambiguous because they contain
"numerous undefined terms," such as "sex toy or device" and "sexual activities." (Def. Mot. 4 at
14). She asks, for instance, whether "bath oil" would count as a sex toy or device. (Id.). Yet this
argument is simply another attempt to imbue ambiguity after the fact into commonly used words
with common sense meanings. The mere fact that a term could apply equally to several different
objects does not automatically mean that the question is impermissibly vague and can never form
the basis of a perjury charge. See, e.g., H.L.A. Hart, Positivism and the Separation of Law and
Morals, 71 Harv. L. Rev. 593, 607 (1958) ("A legal rule forbids you to take a vehicle into the
public park. Plainly this forbids an automobile, but what about bicycles ?"). Instead, it is well-
settled that "[t]he jury should determine whether the question-as the declarant must have
understood it, giving it a reasonable reading-was falsely answered." Lighte, 782 F.2d at 372. So
130
EFTA00029848

=== Page 3 ===
long as the question involves a phrase "which could be used with mutual understanding by a
questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks
omitted); see United States V. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of
ordinary intelligence would not think that a question asking for information regarding 'real estate,
stocks, bonds, or other valuable property' would allow omission of information regarding
money market funds
").
The use of broad or inclusive terms does not render the question fundamentally ambiguous.
As the Second Circuit explained in the context of the term "employment activities," "[t]he broad
language of the question is not fundamentally ambiguous; it is instead designed to capture all
employment activities in an applicant's recent history." United States V. Polos, 723 F. App'x 64,
65-66 (2d Cir. 2018). So too here. A "sex toy or device" is an intelligible phrase with an
understood meaning.
See Sex Toy, Oxford English Dictionary Online,
https://www.oed.com/view/Entry/176989 (last visited February 12, 2021) ("[A] device or object
designed for sexual stimulation (as a dildo, vibrator, etc.) or to enhance sexual pleasure or
performance."). To the extent the term "sexual activities" contains ambiguity, it was defined
earlier in the deposition. (Ex. 11 at 54:4-23 (defining "sexual activities" to include "Kissing,
touching with hands or mouths or other parts of your body" and stating "Whenever I use the term
sexual activities, I will be using it in the way we just defined it."))
The defendant's objections to the next colloquy in the indictment are similarly unavailing
Shortly after the above exchange, the following conversation occurred:
Q. At any time in any of Mr. Epstein's properties, did you engage in
sexual activities with any woman other than when you had three-
way sexual activities with Mr. Epstein?
MR. PAGLIUCA: Object to the form.
131
EFTA00029849

=== Page 4 ===
A. Can you repeat the question?
Q. At any time, in any of Mr. Epstein's properties, did you engage
in sexual activities with any woman other than when you had three-
way sexual activities with Mr. Epstein?
MR. PAGLIUCA: Same objection.
A. No.
Q. Other than yourself and the blond and brunette that you have
identified as having been involved in three-way sexual activities,
with whom did Mr. Epstein have sexual activities?
MR. PAGLIUCA: Objection to form and foundation
A. I wasn't aware that he was having sexual activities with anyone
when I was with him other than myself.
Q. I want to be sure that I'm clear. Is it your testimony that in the
1990s and 2000s, you were not aware that Mr. Epstein was having
sexual activities with anyone other than yourself and the blond and
brunette on those few occasions when they were involved with you?
A. That is my testimony, that is correct.
(Ex. 11 at 91:8-92:16)
The defendant primarily argues that her answers were literally true. In the defendant's
telling, the phrase "[w]hen I was with him," refers not to the duration of the defendant's
relationship with Epstein, but instead to only those moments when she was in the act of having sex
with Epstein and either the blond or brunette identified above. (Def. Mot. 4 at 16). Accordingly,
as the defendant would have it, the question asked whether any of Epstein and the defendant's
three-person sexual encounters involved a fourth person, the answer to which is no, she argues,
because three-person sexual activities by definition cannot involve four people. And in any event,
she further argues, because the question asked the defendant about the 1990s and 2000s, it
therefore covered any "sexual activities' spanning more than a millennium." (Id. at 16-17).
132
EFTA00029850

=== Page 5 ===
The defendant, therefore, argues that the questioner asked whether a logically impossible
event occurred or will occur at some point over the course of a millennium. But the defendant's
professed confusion-which again was not raised during the deposition itself-ignores the plain
and obvious context of the question, which did not refer to a time period far exceeding the human
life span, and was not limited to only the times in which the defendant was in the act of having sex
with Epstein. Plainly, a jury could find that the defendant correctly understood the question when
she answered it in July 2016, and that she ascribed a natural meaning to the words used in the
questions, and not the tortured illogical meaning she now assigns to those questions: whether,
during the course of her relationship with Epstein, she was aware of anyone other than herself
having sexual relations with Epstein. The Government expects its evidence to show that she was.
See, e.g., Indictment 1 (stating that the defendant "assisted, facilitated, and contributed to"
Epstein's sexual abuse of minors). Ata minimum, the defendant's answers were not "literally true
under any conceivable interpretation of the questions." Lighte, 782 F.2d at 374. And the
defendant's professed confusion now and proposed illogical reading of the questions in the instant
motion does not render them fundamentally ambiguous. See Bonacorsa, 528 F.2d at 1221 ("A
defense to a charge of perjury may not be established by isolating a statement from context, giving
it in this manner a meaning entirely different from that which it has when the testimony is
considered as a whole."). Accordingly, a jury should be permitted to determine what meaning the
defendant ascribed to those questions and whether her answers were in fact false.
Finally, the defendant answered the following questions:
Q. Did you ever give a massage to anyone other than Mr. Epstein at
any of Mr. Epstein's properties?
A. First of all, I never said I gave Mr. Epstein a massage.
133
EFTA00029851

=== Page 6 ===
Q. I will ask that question if you want, but I was focusing on people
other than Mr. Epstein right now.
A. I don't give massages.
Q. Let's just tie that down. It is your testimony that you've never
given anybody a massage?
A. I have not given anyone a massage.
Q. You never gave Mr. Epstein a massage, is that your testimony?
A. That is my testimony.
Q. You never gave [Minor Victim-2] a massage is your testimony?
A. I never gave [Minor Victim-2] a massage.
(Ex. 11 at 112:17-113:12).
The defendant argues that these questions were fundamentally ambiguous because the
deposition elsewhere discussed both sexual and professional massages. It was unclear, she
explains, what kind of massage the questioner meant. (Def. Mot. 4 at 17.) The defendant's
argument is, yet again, misguided. This line of questioning used broad language, and at no point
during this set of questions did
counsel suggest that the questions were limited to sexual
or professional massages. Cf. Lighte, 782 F.2d at 376 (concluding that the word "you" was
ambiguous when the prior two questions asked about the defendant"as an individual" and then
switched "without indication" to the defendant "as trustee"). The defendant's answers were
unequivocal, with no expressions of confusion or internal contradictions. Cf. Markiewicz, 978
F.2d at 809 (explaining that a question was ambiguous as to whether it asked about the deponent's
personal or professional capacities, in light of the deponent's confusion in the next questions). A
properly instructed jury could conclude that the defendant meant what she said: she never gave
anyone a massage, including Epstein and Minor Victim-2.
134
EFTA00029852

=== Page 7 ===
Government has reviewed the full report and confirmed that there is nothing exculpatory contained
therein. To the contrary, the report inculpates the defendant. Accordingly, the defendant is not
entitled to its immediate disclosure. The Government will produce an unredacted version of this
document together with all other witness statements in advance of trial. 67
Fourth, the defense requests production of pages from a personal diary that is in the custody
of a civilian third party and is not in the custody or control of the Government. (Def. Mot. 10 at
10). Leaving aside the fact that the defense cites no authority for the proposition that the
Government has an obligation to obtain the personal papers of a third party, see United States V.
Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y.2019) ("The Government's Brady obligations extend
only to materials within prosecutors' possession, custody or control or, in appropriate cases, that
of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state
authority involved in the federal prosecution." (quoting United States V. Blaszczak, 308 F. Supp.
3d 736, 742 (S.D.N.Y.2018)), the Government has already represented that it has asked the third
party at issue about the materials the defendant purports to seek and that no such materials exist.
In particular, to the extent the defense is concerned with whether there are diary entries from
the
spring of 1996 the Government has already indicated in response to the defendant's second bail
motion that it is aware of none. (See Dkt. No. 100 at 11 n. 2
Because this victim stopped writing
in her journal about a month after that first meeting with Epstein, there are no entries regarding the
subsequent trip she took months later to visit Epstein, during which she met the defendant. This
victim provided the Government with copies of fher journal entries relating to Epstein and informed
the Government that the remaining entries are personal in nature and have nothing to do with
67 As is the case with the other redacted document referenced in this motion, the redacted copy
defense counsel attached as Exhibit D was recovered during the execution of a search warrant for
one of Epstein's devices and was produced to defense counsel in the form in which it was
recovered from the device.
187
EFTA00029853

=== Page 8 ===
Epstein or the defendant.").
In other words, the defendant again seeks supposedly exculpatory
evidence that does not exist. The defendant offers no basis on which to conclude that this
representation is false or that any such evidence does in fact exist. As such, this motion should be
denied.
Fifth, the defendant asks this Court, again without citing any legal authority, to order the
Government to produce copies of all subpoenas it has issued for the defendant's records as part of
its investigation in this case. (Def. Mot. 10 at 11). This incredibly broad request is nothing more
than a fishing expedition inappropriately seeking the details of investigative requests made through
the grand jury process. The defense has cited no legal basis for the Court to direct the Government
to provide the defense with copies of the subpoenas themselves (as opposed to records or other
materials received in response to such subpoenas), let alone every subpoena issued for the
defendant's records during a multi-year and ongoing grand jury investigation. The types of
requests issued by the grand jury have no conceivable bearing on the defense or on any motion the
defense may seek to bring. The Government has already produced to the defense all discoverable
material that it has received in response to subpoenas issued to date during this investigation. In
the absence of any legal authority justifying this request, it should be denied. Additionally, for the
reasons discussed above in Sections I and IV, the defendant is not entitled to discovery or a hearing
relating to her motion to dismiss the Indictment based on the NPA or her motion to suppress
subpoena returns.
Sixth, the defendant asks the Court to direct the Government to immediately disclose any
Brady and Giglio material. (Def. Mot. 10 at 11-13). The motion for disclosure of Brady material
should be denied as moot because the Government has conducted a search for any such material
and has already disclosed any potentially exculpatory information in its possession of which it is
188
EFTA00029854


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=== Page 1 ===
From:
"
To:
)"
Cc:
)"
)"
Subject: RE: Epstein SW returns
Date: Sun, 11 Oct 2020 20:54:42 +0000
Thanks
I'll take a look.
From:
Sent: Sunday, October 11, 2020 12:52 PM
To:
Cc:
(
)
i
Subject: Epstein SW returns
Hi
For the Epstein search warrant database, I saw an email from the following email address that I wanted to flag for further
privilege review, because it may belong to Jack Goldberger, who represented Epstein:
Thanks,
EFTA00030598


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:12:04 +0000
Inline-Images: image001.png
Oh my god don't say things like that lol
From:
(USANYS)
Sent: Thursday, July 02, 2020 13:38
To:
(USANYS)
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
I know it's probably not as satisfying as working o
but keep plugging away, maybe she'll hire
From:
(USANYS)
Sent: Thursday, July 2, 2020 1:27 PM
To:
(USANYS)
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Thank you!!!
From:
USANYS)
Sent: Thursday, July 02, 2020 13:26
To:
(USANYS)
is
(USANYS)
V.
;
(USANYS)
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations guys. Amazing work.
From:
(USANYS)
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
DEP UNITED QUI PRO DOMINA JUSTITIA OF STORICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
EFTA00030367

=== Page 2 ===
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
EFTA00030368

=== Page 3 ===
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
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
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.
EFTA00030369

=== Page 4 ===
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.
EFTA00030370


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=== Page 1 ===
From:
To:
Subject: FW: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 15:36:30 +0000
You all are incredible and I am so proud to be at the Office with you.
you are going to be amazing tomorrow- I look forward to it!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
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
EFTA00031251


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
AFFIDAVIT OF CERTIFICATION
:
PURSUANT TO LOCAL
- V.
:
CRIMINAL RULE 16.1
:
GHISLAINE MAXWELL,
:
20 Cr. 330 (AJN)
:
Defendant.
:
:
X
STATE OF NEW YORK
)
COUNTY OF NEW YORK
:
SS.:
SOUTHERN DISTRICT OF NEW YORK )
, pursuant to Title 28, United States Code, Section 1746, hereby
affirms under penalty of perjury:
1.
I am an Assistant United States Attorney in the Office of Audrey Strauss,
Acting United States Attorney for the Southern District of New York. I am one of the Assistants
who represents the Government in these proceedings.
2.
I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in
good faith with counsel to the defendant, Ghislaine Maxwell, regarding defense counsel's request
that the warden of the Metropolitan Detention Center ("MDC") report directly to the Court and
counsel on the defendant's conditions of confinement, and that the parties have been unable to
reach agreement.
3.
In particular, on November 30, 2020, the Government asked defense counsel
whether they would consent to MDC legal counsel addressing the Court and counsel directly in
writing on the defendant's conditions of confinement. On December 1, 2020, defense counsel
EFTA00030411

=== Page 2 ===
indicated that they would not consent and reiterated their request that the Court summon Warden
Tellez to report directly to the Court and counsel on the defendant's conditions of confinement.
4.
I hereby certify that the foregoing statements made by me are true.
Dated: New York, New York
December 1, 2020
Laca Pomeranty
Assistant United States Attorney
Telephone:
2
EFTA00030412


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=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
Subject: Request re Ghisliane Maxwell
Date: Thu, 07 Jan 2021 21:35:28 +0000
Good afternoon,
At the request of defense counsel, our office is preparing a new drive with a copy of discovery material that was
previously produced to Ghislaine Maxwell on a CD, but which she has been unable to view. The drive will be ready
tomorrow. Today, defense counsel asked that Maxwell be able to review those materials over this coming weekend, but
no one from our office is available to hand deliver the drive tomorrow, and we understand that Maxwell would not
receive a FedEx package sent out tomorrow until next week. Defense counsel has offered to pick the drive up from our
office and hand deliver it to the MDC themselves tomorrow. Would that be permissible?
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00030947


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10415581 approved by
, now awaiting further
approval
Date: Wed, 10 Jul 2019 22:16:52 +0000
Importance: Normal
Dear
Travel authorization 10415581 has been approved by
now awaiting further approval.
Trip ID: 10415581
Traveler name:
Purpose: R19NYS13653 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-07-11 - 2019-07-14
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.
EFTA00030292


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=== Page 1 ===
From:
Subject:
Date: Mon, 10 Jun 2019 17:45:00 +0000
Importance: Normal
Attachments:
Hi
Can you make out, from the handwriting, the
phone number on this message? If you can find a service provider
for it, I'll issue a subpoena. Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030154


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 11061409 has received final approval
Date: Fri, 21 Feb 2020 18:54:52 +0000
Importance: Normal
Dear
Travel authorization 11061409 has received final approval.
Trip ID: 11061409
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13400 - Epstein Investigation Witness interviews
Destination: Beverly Hills, CA, United States
Dates: 2020-02-26 - 2020-03-03
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.
EFTA00031714


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=== Page 1 ===
Analytics
Home
Tweets
Audiences
Events
More
SDNYnews
Tweet activity
Last 28 Days
-
Your Tweets earned 2.1M impressions over this 28 day period
2.0M
YOUR TWEETS
During this 28 day
143.9K impressi
1.0M
Gro
au
5
Try P
Jun 16
Jun 23
Jun 30
Jul 7
Tweets
Top Tweets
Tweets and replies
Promoted
Engagements
Impressions
Engagements
Engagement rate
Showing 28 days wit
US Attorney SDNY @SDNYnews . Jul 8
3,173,370
158,969
5.0%
Engagement rate
If you believe you are a victim of Jeffrey Epstein, or have
2.0%
information about the conduct alleged in the Indictment
unsealed today, please call 1-800-CALL FBI
pic.twitter.com/f3ZMThOxJX
View Tweet activity
m
EFTA00030185


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=== Page 1 ===
DIESER REISEPASS GILT FÜR ALLE STAATEN DER WELT
CE PASSEPORT EST VALABLE POUR TOUS LES PAYS DU MONDE
THIS PASSPORT IS VALID FOR ALL COUNTRIES OF THE WORLD
DISTERREIGN ERREICH Sepund
DIE GÜLTIGKEIT DIESES REISEPASSES ENDET AM
LA VALIDITE DE CE PASSEPORT EXPIRE LE
THE VALIDITY OF THIS PASSPORT EXPIRES
21. Mai 1987
OESTE
Bundespolizeidinattion Wien
SCHILLING 100 LEICH
Behörde
Autorité
Authority
09
21. Mai 1982
Ort und Datum
Lieu et date
Place and date
100 100
Oberkommissär
Die Gültigkeitsdauer dieses Reisepasses wird verlängert bis
La validité de ce passeport est prorogée jusqu'au
The validity of this passport is renewed until
Stempel-
Behörde
marke
Autorité
Authority
Ort und Datum
Lieu et date
Place and date
Unterschrift / Signature / Signature
Die Gültigkeitsdauer dieses Reisepasses wird verlängert bis
La validité de ce passeport est prorogée jusqu'au
The validity of this passport is renewed until
Stempel-
Behörde
marke
Autorité
Authority
Ort und Datum
Lieu et date
Place and date
5
Unterschrift / Signature / Signature


c1: EFTA00030243
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030243.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: search warrant
Date: Sun, 07 Jul 2019 03:01:33 +0000
Importance: Normal
Attachments: Second_New_York_Residence_SW.v3.docx
Please call me once you've reviewed-thanks!
Assistant United States Attorney
Southern District of New York
EFTA00030243


c1: EFTA00031403
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031403.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE:
Date: Thu, 31 Oct 2019 13:31:19 +0000
Sure.
I'm leaving early today for trick or treating, but will still be around then.
From:
(USANYS)
Sent: Thursday, October 31, 2019 9:31 AM
To:
(USANYS)
Subject: Fwd:
Okay for me - good for you?
Sent from my iPhone
Begin forwarded message:
From:
"
(NY) (FBI)"
Date: October 31, 2019 at 8:31:20 AM EDT
To:
(USANYS)"
(USANYS)"
Subject: RE:
Want to do a call at 3?
-
On Oct 30, 2019 6:29 PM,
(USANYS)"
wrote:
We met with our team this afternoon. You have time to catch up tomorrow or Friday afternoon?
From:
(NY) (FBI)
Sent: Wednesday, October 30, 2019 3:44 PM
To:
(USANYS)
is
(USANYS)
Subject:
Thoughts on Epstein status meeting?
-
EFTA00031403


c1: EFTA00030547
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030547.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: US V. Epstein
Date: Tue, 12 Nov 2019 19:40:37 +0000
Thanks very much - if you could please give the DVDs to
(cc'd here) for case file storage, that would be
great.
And on the work product, I think it probably would make sense to take a look before it all gets uploaded to Relativity -
what's the easiest way to do that? The entire team is unfortunately traveling from tomorrow through Friday, but we can
talk / meet early next week if that's the most convenient.
thanks,
From:
Sent: Tuesday, November 12, 2019 11:16
To:
Subject: US V. Epstein
Hello
The vendor has finished the document unitization and coding of the data from the 56 DVD files. Please let me know when
you are in your office and I will return the DVD's to you, and also please let me know if you wish to review the vendor's
work.
Thank you.
EFTA00030547


c1: EFTA00031307
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031307.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: United States V. Epstein
Date: Fri, 30 Aug 2019 20:10:55 +0000
Thanks! Have a great weekend.
> On Aug 30, 2019, at 4:07 PM,
wrote:
> We did - attached.
> thanks,
> > > > > > > > > > >
Original Message
> From:
> Sent: Thursday, August 29, 2019 23:24
> To:
> Cc:
> Subject: United States V. Epstein
> Hi
Did y'all order a transcript of this week's hearing? If not, will you point us in the right direction to order one?
> Thanks!
> <J8RpEPSf.pdf>
EFTA00031307


c1: EFTA00030126
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030126.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
NYC DEPARTMENT OF FINANCE
OFFICE OF THE CITY REGISTER
This page is part of the instrument. The City
Register will rely on the information provided
by you on this page for purposes of indexing
this instrument. The information on this page
will control for indexing purposes in the event
of any conflict with the rest of the document.
2011122700736001004E0B2B
RECORDING AND ENDORSEMENT COVER PAGE
PAGE 1 OF 4
Document ID: 2011122700736001
Document Date: 12-23-2011
Preparation Date: 12-28-2011
Document Type: DEED
Document Page Count: 3
PRESENTER:
RETURN TO:
TITLEASSOCIATES - PICK-UP/ AGUSTIN
ERIKA KELLERHALS, ESQ
AS AGENT FOR STEWART TITLE
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16
825 THIRD AVENUE - SSR-11-01-9136
ST. THOMAS 00802
NEW YORK, NY 10022
VIRGIN ISLANDS, US
212-758-0050
340-779-2564
jfeldman@titleassociates.com
PROPERTY DATA
Borough
Block Lot
Unit
Address
MANHATTAN
1386
10
Entire Lot
9 EAST 71ST STREET
Property Type: DWELLING ONLY 1 FAMILY
CROSS REFERENCE DATA
CRFN
or Document ID
or
Year
Reel
Page
or File Number
PARTIES
GRANTOR/SELLER:
GRANTEE/BUYER:
NINE EAST 71ST STREET CORPORATION
MAPLE, INC.
301 EAST 66TH STREET, 10F
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
NEW YORK, NY 10065
ST. THOMAS 00802
VIRGIN ISLANDS, US
FEES AND TAXES
Mortgage
Filing Fee:
Mortgage Amount:
$
0.00
$
125.00
Taxable Mortgage Amount:
$
0.00
NYC Real Property Transfer Tax:
Exemption:
$
0.00
TAXES: County (Basic):
$
0.00
NYS Real Estate Transfer Tax:
City (Additional):
$
0.00
$
0.00
Spec (Additional):
$
0.00
RECORDED OR FILED IN THE OFFICE
TASF:
$
0.00
OF THE CITY REGISTER OF THE
MTA:
$
0.00
CITY OF NEW YORK
NYCTA:
$
0.00
Recorded/Filed
01-10-2012 10:00
Additional MRT:
$
0.00
City Register File No.(CRFN):
TOTAL:
$
0.00
2012000008342
Recording Fee:
$
52.00
1625
Affidavit Fee:
$
0.00
Anneth M Hill
City Register Official Signature
EFTA00030126

=== Page 2 ===
Block: 1386
Lot:
10
Address: 9 East 71st Street
DEED
New York, NY
THIS INDENTURE, made the 23RD day of December, 2011, between NINE EAST 71ST
STREET CORPORATION, a New York corporation, with an address of 301 East 66th Street, 10F,
New York, New York 10065, hereinafter referred to as the party of the first part, and MAPLE,
INC., a U.S. Virgin Islands corporation with an address of 9100 Havensight Port of Sale Ste 15-16,
St. Thomas, VI 00802, hereinafter referred to as the party of the second part,
WITNESSETH:
That the party of the first part, in consideration of the sum of TEN DOLLARS ($10.00) and other
good and valuable consideration paid by the party of the second part, does hereby grant and release
unto the party of the second part, and the successors and assigns of the party of the second part,
forever:
ALL that certain plot, place or parcel of land, with the buildings and improvements thereon erected,
situate, lying and being in the Borough of Manhattan, City, County and State of New York, bounded
and described as follows:
BEGINNING at a point on the northerly side of 71st Street distant 225 feet easterly from the corner
formed by the intersection of the easterly side of 5th Avenue with the northerly side of 71st Street;
running
thence Easterly along the northerly side of 71st Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the center line of the block
between 71" and 72nd Streets;
thence Westerly along the said center line and parallel with 71st Street 50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the northerly side of 71" Street at
the point or place of beginning.
TOGETHER with all right, title and interest, if any, of the party of the first part in and to any
streets and roads abutting the above described premises to the center lines thereof; TOGETHER
with the appurtenances and all the estate and rights of the party of the first part in and to said
premises; TO HAVE AND TO HOLD the premises herein granted unto the party of the second
part, and the successors and assigns of the party of the second part, forever.
AND said party of the first part covenants that the party of the first part has not done or suffered
anything whereby the said premises have been encumbered in any way whatsoever, except as
aforesaid.
AND the party of the first part, in compliance with Section 13 of the Lien Law, covenants that the
party of the second part will receive consideration for this conveyance and will hold the right to
receive such consideration as a trust fund to be applied first for the purposes of paying the cost of
the improvement and will apply the same first to the payment of the cost of the improvement
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
EFTA00030127

=== Page 3 ===
before using any part of the total of the same for any other purpose. The word "party" shall be
construed as if it read "parties" wherever the sense of this indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year
first above written.
WITNESSES
C NINE EAST Its STREET
GRANTOR:
CORPORATION
Bett my Seary
BY: JEFFREY E. EPSTEIN,
President
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
EFTA00030128

=== Page 4 ===
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 2320 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Jeffrey E. Epstein, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual who subscribed to the within instrument, and
acknowledged to me that he executed the same in his capacity as the President of Nine East 71st
Street Corporation, a New York corporation (the "Corporation"), the Grantor therein, and that by
his signature on the within instrument, the Corporation executed the within instrument.
& Notary Public
Erika A. Kellerhals
san
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory or Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared GREGO J. FERGUSON , personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that HE resides in the United States Virgin Islands; that HE knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HIS name as a witness thereto.
a Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of S. Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared BRETT GEARY
, personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that ate resides in the United States Virgin Islands; that SHE knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HER name as a witness thereto.
G Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virdinistends
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
EFTA00030129

=== Page 5 ===
NYC DEPARTMENT OF FINANCE
OFFICE OF THE CITY REGISTER
2011122700736001004SC5AA
SUPPORTING DOCUMENT COVER PAGE
PAGE 1 OF 1
Document ID: 2011122700736001
Document Date: 12-23-2011
Preparation Date: 12-28-2011
Document Type: DEED
ASSOCIATED TAX FORM ID: 2011122700132
SUPPORTING DOCUMENTS SUBMITTED:
Page Count
RP - 5217 REAL PROPERTY TRANSFER REPORT
2
EFTA00030130

=== Page 6 ===
Affidavit of Compliance with Smoke Detector Requirement for One and-Two Family Dwellings
AFFIDAVIT OF COMPLIANCE
WITH SMOKE DETECTOR REQUIREMENT
FOR ONE- AND TWO-FAMILY DWELLINGS
State of New York
)
) SS.:
County of
)
The undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee of
the real property or of the cooperative shares in a cooperative corporation owning real property located at
9 EAST 71ST STREET
,
,
Street Address
Unit/Apt.
MANHATTAN
New York,
1386
10
(the "Premises");
Borough
Block
Lot
That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one- or
two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in
compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of
the City of New York concerning smoke detecting devices;
That they make affidavit in compliance with New York City Administrative Code Section 11-2105 (g). (The
signatures of at least one grantor and one grantee are required, and must be notarized).
Name of Grantor (Type or Print)
Name of Grantee (Type or Print)
Signature of Grantor
Signature of Grantee
Sworn to before me
Sworn to before me
this
date of
20
this
date of
20
See 0 ve
These statements are made with the knowledge that a willfully false representation is unlawful and is punishable as
a crime of perjury under Article 210 of the Penal Law.
NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY
6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE- OR TWO-FAMILY DWELLING, OR A
COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING,
WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT.
1
2011122700132101
EFTA00030131

=== Page 7 ===
Affidavit of Compliance with Smoke Detector Requirement for One and-Two Family Dwellings
AFFIDAVIT OF COMPLIANCE
WITH SMOKE DETECTOR REQUIREMENT
FOR ONE- AND TWO-FAMILY DWELLINGS
State of New York
)
) SS.:
County of
)
The undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee of
the real property or of the cooperative shares in a cooperative corporation owning real property located at
9 East 71st Street
XXXXXX
Street Address
Unit/Apt.
Manhattan
New York, 1386
10
(the "Premises");
Borough
Block
Lot
That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one- or
two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in
compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of
the City of New York concerning smoke detecting devices;
That they make affidavit in compliance with New York City Administrative Code Section 11-2105 (g). (The
signatures of at least one grantor and one grantee are required, and must be notarized).
Nine East 71st Street Corporation
Maple, Inc.
Name of Grantor (Type or Print)
Name of Grantee (Type or Print)
Signature of Grantor
Signature of Grantee
Sworn to before me
Sworn to before me
this
23RD
date of
December
2011
this
83RD
date
of
December
2011
Erika A. Kellerhals
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
STARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
Territory of the U.S. Virgin Islands
These statements are rhade with the knowledge that a willfully false representation is unlawful and is punishable
a crime of perjury under Article 210 of the Penal Law.
NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY
6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE- OR TWO-FAMILY DWELLING, OR A
COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING,
WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT.
1
EFTA00030132

=== Page 8 ===
The City of New York
I CETT YORK MIN OF
Department of Environmental Protection
DEP
Bureau of Customer Services
59-17 Junction Boulevard
ENVIRONMENTAL PROTECTION
Flushing, NY 11373-5108
www.nyc.gov/dep
Customer Registration Form for Water and Sewer Billing
Property and Owner Information:
(1) Property receiving service: BOROUGH: MANHATTAN
BLOCK: 1386
LOT: 10
(2) Property Address: 9 EAST 71ST STREET, NEW YORK, NY 10021
(3) Owner's Name:
MAPLE, INC.
Additional Name:
Affirmation:
Your water & sewer bills will be sent to the property address shown above.
Customer Billing Information:
Please Note:
A. Water and sewer charges are the legal responsibility of the owner of a property receiving water and/or
sewer service. The owner's responsibility to pay such charges is not affected by any lease, license or
other arrangement, or any assignment of responsibility for payment of such charges. Water and sewer
charges constitute a lien on the property until paid. In addition to legal action against the owner, a failure
to pay such charges when due may result in foreclosure of the lien by the City of New York, the property
being placed in a lien sale by the City or Service Termination.
B. Original bills for water and/or sewer service will be mailed to the owner, at the property address or to
an alternate mailing address. DEP will provide a duplicate copy of bills to one other party (such as a
managing agent), however, any failure or delay by DEP in providing duplicate copies of bills shall in no
way relieve the owner from his/her liability to pay all outstanding water and sewer charges. Contact DEP
at (718) 595-7000 during business hours or visit www.nyc.gov/dep to provide us with the other party's
information.
Owner's Approval:
The undersigned certifies that he/she/it is the owner of the property receiving service referenced above; that he/she/it
has read and understands Paragraphs A& B under the section captioned "Customer Billing Information"; and that the
information supplied by the undersigned on this form is true and complete to the best of his/her/its knowledge.
Print Name of Owner:
Signature:
Date (mm/dd/yyyy)
Name and Title of Person Signing for Owner, if applicable:
BCS-7CRF-ACRIS REV. B/08
serove
2
2011122700132101
EFTA00030133

=== Page 9 ===
The City of New York
YORK CITY DEPARTMENT OF
Department of Environmental Protection
DEP
Bureau of Customer Services
59-17 Junction Boulevard
(
PROTECTION
Flushing, NY 11373-5108
www.nyc.gov/dep
Customer Registration Form for Water and Sewer Billing
Property and Owner Information:
(1) Property receiving service: BOROUGH: MANHATTAN
BLOCK: 1386
LOT: 10
(2) Property Address: 9 EAST 71ST STREET, NEW YORK, NY 10021
(3) Owner's Name:
MAPLE, INC.
Additional Name:
Affirmation:
Your water & sewer bills will be sent to the property address shown above.
Customer Billing Information:
Please Note:
A. Water and sewer charges are the legal responsibility of the owner of a property receiving water and/or
sewer service. The owner's responsibility to pay such charges Is not affected by any lease, license or
other arrangement, or any assignment of responsibility for payment of such charges. Water and sewer
charges constitute a lien on the property until paid. In addition to legal action against the owner, a failure
to pay such charges when due may result in foreclosure of the lien by the City of New York, the property
being placed in a lien sale by the City or Service Termination.
B. Original bills for water and/or sewer service will be mailed to the owner, at the property address or to
an alternate mailing address. DEP will provide a duplicate copy of bills to one other party (such as a
managing agent), however, any failure or delay by DEP in providing duplicate copies of bills shall in no
way relieve the owner from his/her liability to pay all outstanding water and sewer charges. Contact DEP
at (718) 595-7000 during business hours or visit www.nyc.gov/dep to provide us with the other party's
information.
Owner's Approval:
The undersigned certifies that he/she/it is the owner of the property receiving service referenced above; that he/she/it
has read and understands Paragraphs A & B under the section captioned "Customer Billing Information"; and that the
information supplied by the undersigned on this form is true and complete to the best of his/her/its knowledge.
Print Name of Owner:
Name and Title of Person Signing 2 for Owner, If applicable: JEFFEY E. EPSTEIN, PRES.
Signature:
Date (mm/dd/yyyy) 12.27.11
BCS-7CRF-ACRIS REV.8/08
2
2011122700132101
EFTA00030134

=== Page 10 ===
CITIZES
FOR CITY USE ONLY
C1. County Code
C2. Date Deed
/
REAL PROPERTY TRANSFER REPORT
Recorded
"DEC 28 2011
Day
STATE OF NEW YORK
STATE BOARD OF REAL PROPERTY SERVICES
C3. Book
C4. Page
OR
RP - 5217NYC
C5. CRFN
PROPERTY INFORMATION
1. Property
9
EAST 71ST STREET
MANHATTAN
10021
Location
STREET NUMBER
STREET NAME
BOROUGH
ZIP CODE
MAPLE, INC.
2. Buyer
Name
LAST NAME / COMPANY
FIRST NAME
LAST NAME / COMPANY
FIRST NAME
3. Tax
Indicate where future Tax Bills are to be sent
Billing
if other than buyer address (at bottom of form)
Address
LAST NAME , COMPANY
FIRST NAME
STREET NUMBER AND STREET NAME
CITY OR TOWN
STATE
ZIP CODE
4. Indicate the number of Assessment
1
4A. Planning Board Approval - N/A for NYC
Roll parcels transferred on the deed
# of Parcels OR
Part of a Parcel
4B. Agricultural District Notice - N/A for NYC
5. Deed
Check the boxes below as they apply:
Property
X
OR
6. Ownership Type is Condominium
FRONT FEET
DEPTH
Size
ACRES
7. New Construction on Vacant Land
NINE EAST 71ST STREET CORPORATION
8. Seller
Name
LAST NAME / COMPANY
FIRST NAME
LAST NAME COMPANY
FIRST NAME
9. Check the box below which most accurately describes the use of the property at the time of sale:
A
One Family Residential
C
Residential Vacant Land
E
Commercial
G
Entertainment/Amusement
I
Industrial
B
2 or 3 Family Residential
D
Non-Residential Vacant Land
F
Apartment
H
Community Service
J
Public Service
SALE INFORMATION
14. Check one or more of these conditions as applicable to transfer:
10. Sale Contract Date
12/23/2011
A
Sale Between Relatives or Former Relatives
Month
Day
Year
B
Sale Between Related Companies or Partners in Business
C
One of the Buyers is also a Seller
11. Date of Sale / Transfer
12/23/2011
D
Buyer or Seller is Government Agency or Lending Institution
Month
Day
Year
E
Deed Type not Warranty or Bargain and Sale (Specify Below)
F
Sale of Fractional or Less than Fee Interest Specify Below)
12. Full Sale Price $
0
G
Significant Change in Property Between Taxable Status and Sale Dates
(Full Sale Price is the total amount paid for the property including personal property.
H
Sale of Business is Included in Sale Price
This payment may be in the form of cash, other property or goods, or the assumption of
I
Other Unusual Factors Affecting Sale Price Specify Below)
mortgages or other obligations.) Please round to the nearest whole dollar amount.
J
None
13. Indicate the value of personal
property Included In the sale
ASSESSMENT INFORMATION - Data should reflect the latest Final Assessment Roll and Tax Bill
15. Building Class
A.5
16. Total Assessed Value (of all parcels in transfer)
1294387
17. Borough, Block and Lot / Roll Identifier(s) If more than three, attach sheet with additional identifier(s) )
MANHATTAN 1386 10
seeove
201112270013220104
EFTA00030135

=== Page 11 ===
Ciil / GRER
FOR CITY USE ONLY
C1. County Code
C2. Date Deed
DEC 2 6,L01111
REAL PROPERTY TRANSFER REPORT
Recorded
Month
STATE OF NEW YORK
STATE BOARD OF REAL PROPERTY SERVICES
C3. Book
C4. Page
OR
RP - 5217NYC
C5. CRFN
PROPERTY INFORMATION
1. Property
9
EAST 71ST STREET
MANHATTAN
10021
Location
STREET NUMBER
STREET NAME
BOROUGH
ZIP CODE
MAPLE, INC.
2. Buyer
Name
LAST NAME / COMPANY
FIRST NAME
LAST NAME , COMPANY
FIRST NAME
3. Tax
Indicate where future Tax Bills are to be sent
Billing
if other than buyer address (at bottom of form)
Address
LAST NAME , COMPANY
FIRST NAME
STREET NUMBER AND STREET NAME
CITY OR TOWN
STATE
ZIP CODE
4. Indicate the number of Assessment
1
4A. Planning Board Approval - N/A for NYC
Roll parcels transferred on the deed
# of Parcels OR
Part of a Parcel
4B. Agricultural District Notice - N/A for NYC
6. Deed
Check the boxes below as they apply:
Property
X
OR
6. Ownership Type is Condominium
Size
FRONT FEET
DEPTH
ACRES
7. New Construction on Vacant Land
NINE EAST 71ST STREET CORPORATION
8. Seller
Name
LAST NAME COMPANY
FIRST NAME
LAST NAME COMPANY
FIRST NAME
9. Check the box below which most accurately describes the use of the property at the time of sale:
A
 One Family Residential
C
Residential Vacant Land
E
Commercial
G
Entertainment/Amusement
I
Industrial
B
2 or 3 Family Residential
D
Non-Residential Vacent Land
F
Apartment
H
Community Service
J
Public Service
SALE INFORMATION
14. Check one or more of these conditions as applicable to transfer:
10. Sale Contract Date
12/23/2011
A
Sale Between Relatives or Former Relatives
Month
Day
Year
B
Sale Between Related Companies or Partners in Business
C
One of the Buyers is also a Seller
11. Date of Sale / Transfer
12/23/2011
D
Buyer or Seller is Government Agency or Lending Institution
Month
Day
Year
E
Deed Type not Warranty or Bargain and Sale (Specify Below)
F
Sale of Fractional or Less than Fee Interest Specify Below)
12. Full Sale Price $
0
G
Significant Change in Property Between Taxable Status and Sale Dates
(Full Sale Price is the total amount paid for the property including personal property.
H
Sale of Business is Included in Sale Price
This payment may be in the form of cash, other property or goods, or the assumption of
I
Other Unusual Factors Affecting Sale Price Specify Below)
mortgages or other obligations.) Please round to the nearest whole dollar amount.
J
None
13. Indicate the value of personal
property Included In the sale
ASSESSMENT INFORMATION - Data should reflect the latest Final Assessment Roll and Tax Bill
15. Building Class
A.5
16. Total Assessed Value (of all parcels In transfer)
1294387
17. Borough, Block and Lot / Roll Identifier(s) If more than three, attach sheet with additional identifier(s)
MANHATTAN 1386 10
201112270013220102
EFTA00030136

=== Page 12 ===
CERTIFICATION
I certify that all of the Items of Information entered on this form are true and correct (to the best of my knowledge and belief) and
understand that the making of any willful false statement of material fact herein will subject me to the provisions of the penal law relative to
the making and filing of false instruments.
BUYER
BUYER'S ATTORNEY
ERIKA KELLERHALS, ESQ
BUYER SIGNATURE
DATE
LAST NAME
FIRST NAME
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
340
779-2564
STREET NUMBER
STREET NAME (AFTER SALE)
AREA CODE
TELEPHONE NUMBER
ST. THOMAS
SELLER
00802
CITY OR TOWN
STATE
ZIP CODE
SELLER SIGNATURE
DATE
PROVINCE
/POSTAL CODE
COUNTRY
VIRGIN ISLANDS, US
serve
2011122700132201
EFTA00030137

=== Page 13 ===
CERTIFICATION
I certify that all of the Items of Information entered on this form are true and correct (to the best of my knowledge and belief) and
understand that the making of any willful false statement of material fact herein will subject me to the provisions of the penal law relative to
the making and filling of false Instruments.
BUYER SIGNATURE M
BUYER
BUYER'S ATTORNEY
12/27/11
ERIKA KELLERHALS, ESQ
DATE
LAST NAME
FIRST NAME
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
340
779-2564
STREET NUMBER
STREET NAME (AF SALE)
AREA CODE
TELEPHONE NUMBER
ST. THOMAS
00802
CITY OR TOWN
STATE
ZIP CODE
PROVINCE
POSTAL CODE
BELLER 2
12/27/11
DATE
COUNTRY VIRGIN ISLANDS, US
2011122700132201
EFTA00030138

=== Page 14 ===
T 601
Manderd N R.T.C. Forms *** Bargala a an and
wa granter's -
REELI617 PABE2412
JULIOS BLUMBERS. INC. LAW BLANK PUBLISHERS
CONSULT YOUR LAWYER BEFORE SIGNING THIS INSTRUMENT THIS INSTRUMENT SHOULD BE USED BY LAWYERS ONLY
AS of
THIS INDENTURE, made/the 6th day of September nineteen hundred and Eighty-Nine
BETWEEN BIRCH WATHEN SCHOOL, INC., having an address at
9 East 71st Street, New York, New York
party of the first part, and NINE EAST 71ST STREET CORPORATION, having
an address at 41 South High Street, Suite 3710
Columbus, Ohio 43215
party of the second part,
WITNESSETH, that the party of the first part, in consideration of Ten Dollars and other valuable consideration
paid by the party of the second part, does hereby grant and release unto the party of the second part, the heirs
or successors and assigns of the party of the second part forever,
ALL that certain plot, piece or pareel of land. with the buildings and improvements thereon crected. situate,
lying and being in the Borough of Manhattan, City, County and State of New York,
bounded and described as follows:
REGINNING at a point on the northerly side of 71st Street distant 225 feet
easterly from the corner formed by the intersection of the easterly side of
5th Avenue with the northerly side of 71st Street; running
thence Easterly along the northerly side of 71st Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the centre
line of the block between 71st and 72nd Streets:
thence Westerly along the said center line and parallel with 71st Street
50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the
northerly side of 71st Street at the point or place of BEGINNING.
This deed is executed in accordance with Supreme Court Order of
the State of New York held in and for the County of New York
on the 6th day of February, 1989, filed as Index No. 2225/89.
TOGETHER with all right. title and interest, if any. of the party of the first part in and to any streets and
roads sbutting the above described premises to the center lines thereof: TOGETHER with the appurtenances
and all the catate and rights of the party of the first part in and to said premises; TO HAVE AND TO HOLD
the premises herein granted unto the party of the second part. the heirs or successors and assigns of the party of
the second part forever.
AND the party of the first part covenants that the party of the first part has not done or suffered anything whereby
the said premises have been encumbered in any way whatever, except as aforessid.
AND the party of the first part. in compliance with Section 13 of the Lien Law, covenants that the party of the first
part will receive the consideration for this conveyance and will hold the right to receive such consideration as a
trust fund to be applied first for the purpose of paying the cost of the improvement and will apply the same first to
the payment of the cost of the improvement before using any part of the total of the same for any other purpose.
The word "party" shail be construed as if it read "parties" whenever the sense of this Indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year first above
written.
IN PRESENCE OF:
BIRCH WATHEN SCHOOL INC.
By:
Philip S.
Chairman and President

=== Page 15 ===
HPDA
STATE of NEW YORK,
⑉
STATE OF NEW YORK, COUNTY OF
⑉
On the
day of
19 # before me
On the
day of
19 . before me
personally came
personally came
to me known to be the individual described in and who
to me known to be the individual described in and who
executed the foregoing instrument, and acknowledged that
executed the foregoing instrument, and acknowledged that
executed the same.
executed the same.
STATE 00 NEW YORK, COUNTY OF New York
⑉
STATE of NEW YORK, COUNTY OF
⑉
On the day of September 19 89. before me
On the
day of
19 , before me
personally came Philip S. Sassower
personally came
to ine known, who, being by me duly sworn, did depose and
the subscribing witness to the foregoing instrument, with
say that he resides at No. part survice
whom I am personally acquainted, who, being by me duly
N4,
1
sworn. did depose and say that be resides at No.
that he is the Chairman and President
of Birch Wathen School, Inc,
I
that he knows
the corporation described
in and which executed the foregoing instrument; that -
knows
to be the individual
the
real
of
said
-
alliwed
said:
described in and who executed the foregoing instrument:
each
that
that he, said subscribing witness, was present and saw
allined by order of the board of directors of said corpora.
tion,
execute the same; and that he, said witness,
he signed hisname theretor by like order.
at the same time subscribed h name as witness thereto.
Rhylan Cassord
Notar Public
PHYLLIS CASSORLA
MOTARY PUBLIC State of New York
No. 4770944
Commission Expires January at. 1991
Qualified in Harsaw County
30490
Bargain and Sale Deab
SECTION 5
WITH COVERANT AGAINST GRANTOR'S ACTS
TITLE No. -11-00-0021 M211019
BLOCK
1386
LOT
10
BIRCH WATHEN SCHOOL, INC.
COUNTY OR TOWN Manhattan
$ 52,800-
Promises: 9 East 71st street
REAL ESTATE
TO
0735
SEP 1 1989
RETURN BY MAIL TO:
TRANSFER TV:
NINE EAST 71ST STREET CORPORATION NEW YORK
Jack S. Levey, Esq.
COUNTY
Schwartz, Kelm, Warren & Rubinstein
41 South High Street
Columbus, Ohio
Zip No.
43215
Less Terrae, Ltd.
331 Madison Avenue
New York, N.Y. 10017
(212) 599-1300
with
19
DEED
236899
52,800
$19.00
GNAFF
236900
RECORDED IN NEW YORK COUNTY
OFFICE OF THE CITY REGISTER
7625
$3.00
il 1 I y I
1889 SEP 11 P 3 03
R
in sorow
CITY MEGISTER
BST $
- 1PR
or
2

=== Page 16 ===
19-J-9358AB.txt
Page 1/5
Title No: 5344-19-J-9358
COUNTY CLERK SEARCH ( 07/21/2019 )
COMPANY NAME: ( MAPLE INC. )
COUNTY: ( MANHATTAN )
Run Date: 07/01/2009 To: 07/21/2019
JUDGMENTS -
Manhattan County from ( 06/87 to 07/18/19 )
Search Parameters- CORP:MAPLE INC.
All Types Of Liens
END RETURNS
PVB - (Parking Violations Bureau - Ending Date 06/26/19)
Search Parameters- CORP:MAPLE INC.
END RETURNS
(Environmental Control Board (Fire and Building) Ending Date 05/31/19)
Search Parameters- CORP:MAPLE INC.
MAPLE MADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 41668695K
Date-08/16
Amt: $300.00
MAPLE MADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 186878552
Date-09/15
Amt: $300.00
MAPLE SHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 204922640
Date-12/18
Amt: $300.00
MAPLE TREE CONSTRUCTION INC
83 HESTER STREET
NEW YORK, NY 10002
ECB Violation No.: 182521222
Date-02/14
Amt: $500.00
MAPLE TREE CONSTRUCTION INC
83 HESTER STREET
NEW YORK, MY 10002
ECB Violation No.: 182637630
Date-08/14
Amt: $31.56
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 40117082K
Date-12/18
Amt $300.00
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
Sunday July 21, 2019
1/5
EFTA00030141

=== Page 17 ===
19-J-9358AB.txt
Page 2/5
BROOKLYN, NY 11207
ECB Violation No.: 41585409R
Date-10/12
Amt: $300.00
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 444916442
Date-06/17
Amt: $300.00
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 41344464M
Date-12/11
Amt: $300.00
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 41686941X
Date-08/14
Amt: $25.00
MAPLESHADE PROPERTIES INC
847 LIVIONIA AVE
BROOKLYN, NY 11207
ECB Violation No.: 186876618
Date-12/15
Amt: $300.00
MAPLESHADE PROPERTIES INC
847 LIVONIA AVENUE
BROOKLYN, NY 11207
ECB Violation No.: 203735190
Date-08/18
Amt: $300.00
134 38 MAPLE REALTY INC
134-38 MAPLE AVENUE
FLUSHING, NY 11355
ECB Violation No.: 11614050L
Date-03/18
Amt: $1,050.00
13438 MAPLE REALTY INC
134-38 MAPLE AVENUE
FLUSHING, NY 11355
ECB Violation No.: 11304086J
Date-02/14
Amt: $750.00
END RETURNS
Uniform Commercial Code from ( 10/01/1988 07/18/19 )
Manhattan County
Search Parameters- CORP:MAPLE INC.
END RETURNS
Federal Tax Liens from ( 01/94 - 07/18/19 )
Manhattan, Bronx, Queens, Kings County
Search Parameters- CORP:MAPLE INC.
END RETURNS
TAB (Transit Adjudication Bureau - from 07/14/1998 to 05/22/19)
Search Parameters- CORP:MAPLE INC.
2/5
Sunday July 21, 2019
EFTA00030142

=== Page 18 ===
19-J-9358AB.txt
Page 4/5
COMPANY NAME: ( NINE EAST 71ST STREET )
COUNTY: ( MANHATTAN )
Run Date: 07/01/2009 To: 07/21/2019
JUDGMENTS -
Manhattan County from ( 06/87 to 07/18/19 )
Search Parameters- CORP:NINE EAST 71ST STREET
All Types Of Liens
END RETURNS
PVB - (Parking Violations Bureau - Ending Date 06/26/19)
Search Parameters- CORP:NINE EAST 71ST STREET
END RETURNS
(Environmental Control Board (Fire and Building) - Ending Date 05/31/19)
Search Parameters- CORP:NINE EAST 71ST STREET
END RETURNS
Uniform Commercial Code from ( 10/01/1988 - 07/18/19 )
Manhattan County
Search Parameters- CORP:NINE EAST 71ST STREET
END RETURNS
Federal Tax Liens from ( 01/94 - 07/18/19 )
Manhattan, Bronx, Queens, Kings County
Search Parameters- CORP:NINE EAST 71ST STREET
END RETURNS
TAB - (Transit Adjudication Bureau - from 07/14/1998 to 05/22/19)
Search Parameters- CORP:NINE EAST 71ST STREET
END RETURNS
4/5
Sunday July 21, 2019
EFTA00030143

=== Page 19 ===
19-J-9358AB.txt
Page 5/5
Block: ( 01386 )
Lot: ( 00010 )
COUNTY: ( MANHATTAN )
Run Date: 07/01/2009 To: 07/21/2019
JUDGMENTS -
Manhattan County from ( 06/87 to 07/18/19 )
Search Parameters- Block: 01386
Lot: 00010
All Types Of Liens
Block: 01386 Lot: 00010
Control No. 003887343-01
Book Type -- Lis Pendens - Docket No:
Index # 19 CR.490
Judgment Type: LIS PENDENS
Effective Date: 07/11/2019
Court: Supreme Court
Expiration Date: 07/11/2022
Docket Date: 07/11/2019
Date Received:07/16/2019
Debtor Info:
EPSTEIN, JEFFREY
9
EAST 71ST STREET
NEW YORK NY
10021-
IMAGE IS NOT AVAILABLE
Creditor Info:
UNITED STATES OF AMERICA
Amount: $0.00
COM:07/11/2019-NATURE OF ACTION: FORFEITURE THERERO
DOCUEMENT #19A
END RETURNS
Emergency Repair Manhattan County
Search Parameters- Block:01386
Lot:0010
(Emergency Repair Ending Date - 06/05/19)
(Balance for work done prior to January 1, 2000)
END RETURNS
UCC by Block and lot from ( 10/01/1988 - 07/18/19 )
Manhattan County
Search Parameters- Block:01386
Lot: 0010
END RETURNS
Federal Tax lien by Block and lot from ( 01/90 07/18/19 )
Manhattan County
Search Parameters- Block:01386
Lot:0010
END RETURNS
Sunday July 21, 2019
5/5
EFTA00030144

=== Page 20 ===
NYC
Property Tax Bill
Department of Finance
Quarterly Statement
Activity through June 1, 2019
Owner name: MAPLE, INC.
Mailing address:
Property address: 9E. 71ST ST.
MAPLE, INC.
Borough, block & lot: MANHATTAN (1), 01386, 0010
9E. 71ST ST.
NEW YORK NY 10021-4102
Outstanding Charges
$0.00
New Charges
$173,510.58
Amount Due
$173,510.58
Please pay by July 1, 2019
PTS- LD
1400.01
40- 0
Visit us at nyc.gov/finance or call 311 for more information.
105360
NYC
Please include this coupon if you pay by mail or in person. 1-01386-0010
Department of
Finance
Total amount due by July 1, 2019
$173,510.58
If you want to pay everything you owe by July 1, 2019 please pay
$345,286.05
Amount enclosed:
#811473919060101*
Make checks payable & mail payment to:
MAPLE, INC.
NYC Department of Finance
9E. 71ST ST.
P.O. Box 680
NEW YORK NY 10021-4102
Newark NJ 07101-0680
8114739190601 01 1013860010 0000017351058 0000034528605 190701112020000
9
EFTA00030145

=== Page 21 ===
June 1, 2019
NYC
Statement Details
Maple, Inc.
9E. 71st St.
1-01386-0010
Department of Finance
Page 2
Billing Summary
Activity Date Due Date
Amount
Outstanding charges including interest and payments
$0.00
Finance-Property Tax
07/01/2019
$173,510.58
Total amount due
$173,510.58
Tax Year Charges Remaining
Activity Date
Due Date
Amount
Finance-Property Tax
01/01/2020
$173,510.58
Total tax year charges remaining
$173,510.58
If you want to pay everything you owe by July 1, 2019 please pay
$345,286.05
If you pay everything you owe by July 1, 2019, you would save:
$1,735.11
Annual Property Tax Detail
Overall
Tax class 1 - Small Home, Less Than 4 Families
Tax Rate
Current tax rate
20.9190%
Estimated Market Value $55,931,000
Taxes
Billable Assessed Value
$1,658,880
Taxable Value
$1,658,880 X 20.9190%
Tax Before Abatements and STAR
$347,021.16
$347,021.16
Annual property tax
$347,021.16
The NYC Health Department would like to remind property owners that they must remove standing water, where
mosquitos can breed in warm weather. For more information, please visit nyc.gov/health or call 311.
Home banking payment instructions:
1. Log into your bank or online bill pay website.
2. Add the new payee: NYC DOF Property Tax. Enter your account number, which is your boro,
block and lot, as it appears here: 1-01386-0010 You may also need to enter the address for the
Department of Finance. The address is P.O. Box 680, Newark NJ 07101-0680.
3. Schedule your online payment using your checking or savings account.
Did your mailing address change?
If so, please visit us at nyc.gov/changemailingaddress or call 311.
When you provide a check as payment, you authorize us either to use information from your check to make a one-time electronic
fund transfer from your account or to process the payment as a check transaction.
EFTA00030146

=== Page 22 ===
Digital Tax Map - New York City Dept. of Finance (7/18/2019)
64
1
102.
TO
<<
62
of
102.1
100
201
1386
U.S.
61
20217
41
60
3
FOR
=
4
TOTAL
#9
41,
59
so
2020
6
2
30
&
102
&
it;
D
10
To
100
20217
2
46.
12
20
=
$
2020
4
13
1
50
4
14
TORT
E 71 st
11
30
16
20
46,
1R
V
In
D
0
50
100
feet
26
25
25
Copyright 2019 The City of New York
is
Borough Boundary
C50
Condo Flag/Condo Nunber
Tax Block Boundary
A50
Air Right Flag/Lot Number
50
Tax Block Number
S50
Subterranean Right Flag/Lot Number
Tax Lot Boundary
R
REUC Flag
50
Tax Lot Number
Under Water Tax Lot Boundary
50
Condo FKA Tax Lot Number
Other Boundary
50.5
Tax Lot Dimension
1
Possession Hook
+/-5.5
Approximate Tax Lot Dimension
Misc
Miscelaneous Text
1500-1550
Condo Units Range Label
Small Tax Lot Dimension
Building Footprint
Surface Water
EFTA00030147


c1: EFTA00031010
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031010.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Car service
Date: Mon, 19 Aug 2019 18:16:39 +0000
Hi
we need car service to pick up a witness in the Epstein death investigation. She should be picked up
tomorrow at 10 and brought to 1SA. Thank you in advance.
EFTA00031010


c1: EFTA00030231
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030231.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: Gov't Says Epstein Victims Can't Scrap Nonprosecution Deal - Law360
Date: Wed, 26 Jun 2019 10:41:37 +0000
Importance: Normal
ov't Says Epstein Victims Can't Scrap Nonprosecution Deal
By Carolina Bolado
https://www.law360.com/articles/1172511/gov-t-says-
Share us on:
epstein-victims-can-t-scrap-nonprosecution-deal
Law360 (June 25, 2019, 4:07 PM EDT) -- Federal
prosecutors said Monday that billionaire sex offender
Jeffrey Epstein's victims are not entitled to the relief
they're seeking - namely the reopening of the
criminal case against Epstein and an apology - but
offered to participate in a hearing at which victims
can provide statements.
The government said the Crime Victims Rights Act,
under which two of Epstein's victims sued to
challenge the nonprosecution agreement, does not
provide for the relief they want, which includes a
detailed explanation from prosecutors about their
decision, an apology and monetary sanctions.
The court found in the victims' favor in February and
ruled that prosecutors, including then-U.S. Attorney
and current Labor Secretary Alexander Acosta,
violated the CVRA when they signed the
nonprosecution agreement with Epstein without
notifying his victims.
In its response, the government admitted that it
should have communicated with the victims in a
more straightforward and transparent way but said
that does not mean the decision to not prosecute
Epstein was improper. The remedy should have a
EFTA00030231

=== Page 2 ===
nexus to the purpose of the CVRA, which is to give
victims a voice but not to give them decision-making
authority over prosecutors, according to the
government.
"The past cannot be undone; the government
committed itself to the terms of the [nonprosecution
agreement], and the parties have not disputed that
Epstein complied with its provisions," the
government said. "A number of Epstein's victims
subsequently invoked the NPA to enter into civil
settlements with Epstein and, in that respect, also
relied on its terms. Any remedy for the CVRA
violation should thus serve to give the victims a
voice, even though the prosecution decision remains
out of their hands."
The government instead proposed a meeting with the
two plaintiffs, as well as any other Epstein victims
who want to attend, at which a U.S. Department of
Justice representative will discuss the government's
reasoning in resolving the Epstein case.
The government said prosecutors would also
participate in a public court proceeding at which any
Epstein victims can make statements. In addition, all
criminal prosecutors in the U.S. Attorney's Office for
the Southern District of Florida would undergo
additional training on the CVRA and victim
assistance issues.
"While the court cannot unwind the past, the
remedies proposed by the government would give the
victims a meaningful opportunity to have their voices
heard and to understand, if not accept the decisions
made in this matter," the government said.
"Petitioners' requested remedies, on the other hand,
run afoul of the remedial scheme contemplated by the
EFTA00030232

=== Page 3 ===
CVRA, are contrary to law, and may cause
unintended harm to the victims whose interests are
also protected by the CVRA."
U.S. District Judge Kenneth A. Marra granted
summary judgment in February to the two victims,
listed as Jane Does, who sued the government in
2008 alleging that prosecutors had violated the
CVRA with the Epstein deal. The judge said the
government's decision to hide its intentions and to
tell victims to just be patient with the investigation
was "particularly problematic."
Judge Marra rejected the government's claim that the
CVRA requires victims to be notified only of a plea
bargain or a deferred prosecution agreement, both of
which are more common than a nonprosecution
agreement. That reading of the law is "inconsistent
with the goal of the CVRA," according to the judge.
"The expansive context of the CVRA lends itself to
only one interpretation; namely, that victims should
be notified of significant events resulting in
resolution of their case without a trial," Judge Marra
said.
The CVRA grants crime victims a number of rights,
including the right to be informed of public court
proceedings and not to be excluded from those
proceedings. The Miami Herald, in an investigative
report published late last year, printed emails
showing the alleged victims were deliberately
excluded from the deal cut between Acosta, who was
then the U.S. attorney for the Southern District of
Florida, and Epstein's defense team.
Brad Edwards, who represents the victims, said his
clients are disappointed by the government's
EFTA00030233

=== Page 4 ===
response.
"After sifting through self-serving statistics and
variations of the same excuses we have heard for
years, the government took no responsibility for its
clear wrongdoing and suggests that no remedy is the
appropriate ruling," Edwards said. "In fact, it acts
like it is doing the victims a favor by offering to have
its attorneys voluntarily attend training courses. The
pleading was the type of slap in the face that we
expect to see from Mr. Epstein."
Epstein's alleged victims - numbering in the dozens
- claim he lured teenage girls to his Palm Beach,
Florida, mansion to engage in sexual acts. They have
not had the opportunity to testify in court in any
proceeding thus far, according to the Herald report.
Epstein pled guilty in 2008 to state charges involving
solicitation of prostitution and procurement of minors
for prostitution. He spent 13 months in prison and is
registered as a sex offender.
The victims are represented by Bradley Edwards
of Edwards Pottinger LLC, Jay C. Howell of Jay
Howell & Associates PA, John Scarola of Searcy
Denney Scarola Barnhart & Shipley PA, and Paul G.
Cassell of the University of Utah's S.J. Quinney
College of Law.
The government is represented by Byung J. Pak, Jill
E. Steinberg and Nathan P. Kitchens of the U.S.
Attorney's Office for the Northern District of
Georgia.
The case is Doe V. U.S., case number 9:08-cv-80736,
in the U.S. District Court for the Southern District of
Florida.
EFTA00030234

=== Page 5 ===
--Editing by Kelly Duncan.
EFTA00030235


c1: EFTA00030596
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030596.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Question re emails
Date: Sat, 10 Oct 2020 12:17:49 +0000
Ok, will respond.
On Oct 10, 2020, at 8:17 AM,
(USANYS)
wrote:
I agree.
Sent from my iPhone
On Oct 10, 2020, at 8:15 AM,
(USANYS)
wrote:
This seems right to me. First, this goes beyond what we said we would do or told the court we would do.
Second, in any event they are separately gathering any potentially relevant emails from the agent with
victims. Third, we have no reason to believe there were significant gaps in retention or collection for
,
such that any of his emails would be in what we already have.
Begin forwarded message:
From:
)"
Date: October 9, 2020 at 9:05:09 PM EDT
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
i
)"
Subject: Question re emails
Chiefs,
Today, we spoke with SA
, one of the original FBI agents from the Florida investigation of Epstein.
told us he has a number of emails with AUSA
regarding the case. Our view is that we do not need to
collect those emails from
because we have already received thousands of
emails, which were
collected by OPR and should encompass any emails with the FBI about the Epstein case.
is going to send us
any emails he received from victims or witnesses. We also discussed other documents
has in his possession
from the Epstein investigation and asked him to send us any that sounded potentially discoverable.
Please let us know if this approach sounds right to you or if you would like to discuss.
Thanks,
EFTA00030596

=== Page 2 ===
EFTA00030597


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030708.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: Warrants
Date: Tue, 10 Sep 2019 21:14:32 +0000
Attachments: USVI_Devices_SW_v3.docx;SW_for_6_binders_v3.docx
Attached are the final versions of the two warrants we need to swear out. One is for the six binders that were incorrectly
described in our prior warrant for the contents of the suitcases recovered from the New York residence. The second is for
the electronic devices seized in the Virgin Islands.
Please read both of these very closely and give me a call if you see any inaccuracies or errors. Once you're signed off, let
me know, and I'll send these to the Judge.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030708


c1: EFTA00029911
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029911.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 1B5
Evidence
31E-MM-108062 1B5
Item:
Evidence
General
Type:
(U//FOUO) One box containing: 1) FIVE MESSAGE PRINTOUTS PBPD 05-382(1) 2) WHITE PAPER C. J. (2) 3)
MESSAGE M. (3) 4) MESSAGE P.S. (4) 5) MESSAGE A. (5) 6) MESSAGE J.L. (6) 7) MESSAGE T. (7) 8) CLEAR
PLASTIC STICK (8) 9) TWELVE WHITE PAPER - EXPENDITURES PBPD 05-383(1) 10) WHITE PAPER J. (2)
11) WHITE PAPER D. (3) 12) WHITE PAPER C. (4) 13) WHITE PAPER J. (5) 14) WHITE PAPER J. (6) 15)
Description: WHITE PAPER M. (7) 16) WHITE PAPER #
(8) 17) MESSAGE A. PBPD 05-384(1) 18)
WHITE PAPER T. (2) 19) WHITE PAPER J.H. (3) 20) WHITE PAPER F. (4) 21) MESSAGE G.D. (5) 22)
MESSAGE # (6) 23) MESSAGE M.M. H. (7) 24) WHITE PAPER C.W. (8) 25). WHITE PAPER (917) PBPD 05-
385(1) 26) WHITE PAPER A. (2) 27) WHITE PAPER E. (3) 28) WHITE PAPER B. F. (4) 29) WHITE PAPER
S.B.
(5) 30) FOUR WHITE PAPERS (6)
Location:
E03707388 - ECR8
E4640430 ECR8, 14
Barcode: E6516715
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery Location
Holding Office: NY - NEW YORK
Area:
Unavailable in data migrated from
Finalized By:
ACS
Last Inventory: 07/20/2021 12:00 AM
Seizing Individual:
None
Other Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
SDNY_GM_02753568
EFTA00029911

=== Page 2 ===
Chain of Custody FD-192
E6516715
Case ID
:
31E-MM-108062
1B5
Barcode
Accepted
Printed
Reason
Accepted
Printed
Reason
Accepted
Printed
Reason -
Accepted
Printed
Reason: -
Accepted
Printed
Reason:
Accepted
Printed
Reason:
Accepted BY:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Reason:
6/14/19
Signature:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753569
EFTA00029912

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinqui
Date and
Time
Signature
Printed NOT
6/20/19
Reason:
Relinqui
3:00PM
Date and
Time
Signature
Printed No.:
6/24/19
Reason:
2:10p
Relinquire
Date and
Time
Signature
Printed No.:
9/26/19
Reason:
Relinqui
220pn pn
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 5
Barcode: E4229232
E6516715
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753570
EFTA00029913


c1: EFTA00031529
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031529.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:14:53 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 2:13 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
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 UNITED DONING 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
EFTA00031529

=== Page 2 ===
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00031530

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00031531


c1: EFTA00031199
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031199.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell - inmate mail
Date: Fri, 15 Oct 2021 14:27:45 +0000
Attachments: Ltr_to_Ct_re_Legal_Mail_10-14-21.pdf
Hi
Maxwell's counsel filed the attached letter last night, and we've been ordered to respond as soon as possible, and by no
later than 5 pm. Is one of you free soon for a call about this?
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00031199


c1: EFTA00030949
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030949.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 21:32:41 +0000
Inline-Images: image001.png
Thanks
From:
Sent: Thursday, July 2, 2020 5:32 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Nice work team!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF TOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00030949

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00030950

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00030951


c1: EFTA00030998
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030998.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
)"
Subject: Draft Letter re Maxwell for Review - DUE MONDAY 6/7
Date: Sun, 06 Jun 2021 23:53:00 +0000
Attachments: 2021-06-07_GM_letter_update_re_MDC_conditions_v1.docx
Hi
Attached please find the draft of our update letter to the court regarding Maxwell. Would you please review and confirm
that this is accurate?
Thanks very much,
Maurene
Assistant United States Attorney
York
EFTA00030998


c1: EFTA00030774
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030774.pdf
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c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
,
)"
Subject: Draft Epstein Devices SW
Date: Wed, 24 Jun 2020 21:06:20 +0000
Attachments: SW_for_all_JE_electronic_devices_v4.docx.
Chiefs,
Attached for review is a draft search warrant seeking a warrant that expands the scope of our review of the data from the
devices we seized from Epstein. Happy to discuss.
Thanks,
EFTA00030774


c1: EFTA00031693
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031693.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Rule 17 subpoenas
Date: Mon, 03 May 2021 20:39:32 +0000
Attachments: 2021.04.27_Order_re_Rule_17_subpoenas.pdf
Sorry about that - order attached. Thanks!
From:
(USANYS)
Sent: Monday, May 3, 2021 4:34 PM
To:
Subject: RE: Rule 17 subpoenas
Would you mind sending me AJN's order on the subpoena when you can (I think you sent us the one on the pretrial
motions a bit ago...) Thanks.
From:
Sent: Monday, May 3, 2021 3:13 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
is
Subject: Rule 17 subpoenas
Hey
We owe Judge Nathan a letter tomorrow about our views on three of Maxwell's subpoena requests. Attached is a draft
response.
For your reference, I've also attached (1) Judge Nathan's order, and (2) the letters on the subject from Maxwell and Boies
Schiller.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00031693


c1: EFTA00031555
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031555.pdf
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c0:
=== Page 1 ===
7/17/2019
Untitled Document
NYC DEPARTMENT OF FINANCE
OFFICE OF THE CITY REGISTER
This page is part of the instrument. The City
Register will rely on the information provided
by you on this page for purposes of indexing
this instrument. The information on this page
will control for indexing purposes in the event
of any conflict with the rest of the document.
2011122700736001004E0B2B
RECORDING AND ENDORSEMENT COVER PAGE
PAGE 1 OF 4
Document ID: 2011122700736001
Document Date: 12-23-2011
Preparation Date: 12-28-2011
Document Type: DEED
Document Page Count: 3
PRESENTER:
RETURN TO:
TITLEASSOCIATES - PICK-UP/ AGUSTIN
ERIKA KELLERHALS. ESQ
AS AGENT FOR STEWART TITLE
9100 HAVENSIGHT. PORT OF SALE, SUITE 15/16
825 THIRD AVENUE- SSR-11-01-9136
ST. THOMAS 00802
NEW YORK. NY 10022
VIRGIN ISLANDS. US
212-758-0050
340-779-2564
jfeldman@titleassociates.com
PROPERTY DATA
Borough
Block Lot
Unit Address
MANHATTAN
1386
10
Entire Lot
9 EAST 71ST STREET
Property Type: DWELLING ONLY - 1 FAMILY
CROSS REFERENCE DATA
CRFN
or Document ID
or
Year
Reel
Page
or File Number
PARTIES
GRANTOR/SELLER:
GRANTEE/BUYER:
NINE EAST 71ST STREET CORPORATION
MAPLE, INC.
301 EAST 66TH STREET, 10F
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
NEW YORK. NY 10065
ST. THOMAS 00802
VIRGIN ISLANDS, US
FEES AND TAXES
Mortgage
Filing Fee:
Mortgage Amount:
$
0.00
$
125.00
Taxable Mortgage Amount:
$
0.00
NYC Real Property Transfer Tax:
Exemption:
s
0.00
TAXES: County (Basic):
$
0.00
NYS Real Estate Transfer Tax:
City (Additional):
$
0.00
$
0.00
Spec (Additional):
$
0.00
RECORDED OR FILED IN THE OFFICE
TASF:
$
0.00
OF THE CITY REGISTER OF THE
MTA:
S
0.00
CITY OF NEW YORK
NYCTA:
$
0.00
Recorded/Filed
01-10-2012 10:00
Additional MRT:
$
0.00
City Register File No.(CRFN):
TOTAL:
$
0.00
2012000008342
Recording Fee:
S
52.00
1625
Affidavit Fee:
S
0.00
Anneth M Hill
City Register Official Signature
https://a836-acris.nyc.gov/DS/DocumentSearch/Documentimnage/Vlew7o_id=20112700736001
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=== Page 2 ===
7/17/2019
Untitled Document
Block: 1386
Lot:
10
Address: 9 East 71st Street
DEED
New York, NY
THIS INDENTURE, made the 23RD day of December, 2011, between NINE EAST 71ST
STREET CORPORATION, a New York corporation, with an address of 301 East 66th Street, 10F,
New York, New York 10065, hereinafter referred to as the party of the first part, and MAPLE,
INC., a U.S. Virgin Islands corporation with an address of 9100 Havensight Port of Sale Ste 15-16,
St. Thomas, VI 00802, hereinafter referred to as the party of the second part,
WITNESSETH:
That the party of the first part, in consideration of the sum of TEN DOLLARS ($10.00) and other
good and valuable consideration paid by the party of the second part, does hereby grant and release
unto the party of the second part, and the successors and assigns of the party of the second part,
forever:
ALL that certain plot, place or parcel of land, with the buildings and improvements thereon erected,
situate, lying and being in the Borough of Manhattan, City, County and State of New York, bounded
and described as follows:
BEGINNING at a point on the northerly side of 71" Street distant 225 feet easterly from the corner
formed by the intersection of the easterly side of 5th Avenue with the northerly side of 71" Street;
running
thence Easterly along the northerly side of 71" Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the center line of the block
between 71" and 72nd Streets;
thence Westerly along the said center line and parallel with 71" Street 50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the northerly side of 71" Street at
the point or place of beginning.
TOGETHER with all right, title and interest, if any, of the party of the first part in and to any
streets and roads abutting the above described premises to the center lines thereof; TOGETHER
with the appurtenances and all the estate and rights of the party of the first part in and to said
premises; TO HAVE AND TO HOLD the premises herein granted unto the party of the second
part, and the successors and assigns of the party of the second part, forever.
AND said party of the first part covenants that the party of the first part has not done or suffered
anything whereby the said premises have been encumbered in any way whatsoever, except as
aforesaid.
AND the party of the first part, in compliance with Section 13 of the Lien Law, covenants that the
party of the second part will receive consideration for this conveyance and will hold the right to
receive such consideration as a trust fund to be applied first for the purposes of paying the cost of
the improvement and will apply the same first to the payment of the cost of the improvement
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
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=== Page 3 ===
7/17/2019
Untitled Document
before using any part of the total of the same for any other purpose. The word "party" shall be
construed as if it read "parties" wherever the sense of this indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year
first above written.
WITNESSES
C NINE EAST 71 STREET
GRANTOR:
CORPORATION
Bett mg Seary
BY: JEFFREY E. EPSTEIN,
President
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
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=== Page 4 ===
7/17/2019
Untitled Document
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 2390 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Jeffrey E. Epstein, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual who subscribed to the within instrument, and
acknowledged to me that he executed the same in his capacity as the President of Nine East 71"
Street Corporation, a New York corporation (the "Corporation"), the Grantor therein, and that by
his signature on the within instrument, the Corporation executed the within instrument.
Notary of Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory or Virgintslands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 2320 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared GREEP J. FERGUEON , personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that HE resides in the United States Virgin Islands; that HE knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HIS name as a witness thereto.
SA Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of there S. Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared BRETT GEARY
a personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that atc resides in the United States Virgin Islands; that of knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HER name as a witness thereto.
G Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virding
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Cc:
"
(USANYS)"
(USANYS)"
,
"
)"
(USANYS)"
Subject: Re: Maxwell Press Remarks
Date: Mon, 29 Jun 2020 17:21:11 +0000
These are great. Keeping in mind that we may have sensitivities about this exact wording, here's a humbly
suggested pull quote:
"Ghislaine Maxwell wasn't a bystander. And she wasn't just an enabler. She was a participant."
I think with the right inflection this could be powerful. Just a thought
Sent from my iPhone
On Jun 29, 2020, at 12:17 PM,
(USANYS)
wrote:
- Attached is a slightly revised/current version of
planned remarks for any comments or suggestions
you may have.
Thanks,
Ghislaine Maxwell Press Remarks v6.docx>
EFTA00030811


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Nycha
Date: Fri, 20 Dec 2019 21:47:32 +0000
Up to you. Seriously, Monday is wide open, so if that is preferable, we can wait. But I am here if you'd rather get
it over with.
Original Message
From:
(USANYS)
Sent: Friday, December 20, 2019 4:46 PM
To:
(USANYS)
Subject: RE: Nycha
Sorry, I'm back. Want me to come down?
Original Message
From:
(USANYS)
Sent: Friday, December 20, 2019 4:43 PM
To:
(USANYS)
Subject: Re: Nycha
Stopped by but you are not there.
Sent from my iPhone
> On Dec 20, 2019, at 2:06 PM,
(USANYS)
wrote:
>
> Let me know, I'm generally around. Monday is also definitely fine if that's easier. My day is wide open. Just
didn't want to forget about it.
V
>
Original Message
> From:
(USANYS)
> Sent: Friday, December 20, 2019 1:58 PM
> To:
(USANYS)
(USANYS)
> Subject: RE: Nycha
V
>
I should have a few minutes later today -- it's just a packed day. Definitely will have time on Monday.
>
>
Original Message
> From:
(USANYS)
> Sent: Friday, December 20, 2019 1:56 PM
> To:
(USANYS)
i
(USANYS)
> Subject: RE: Nycha
>
>
Let me know if you have two minutes to talk about the Epstein Fund. Also around Monday if that's better.
V
>
Original Message
> From:
(USANYS)
> Sent: Friday, December 20, 2019 1:42 PM
EFTA00031584

=== Page 2 ===
> To:
(USANYS)
i
(USANYS)
> Subject: RE: Nycha
>
> Perfect. Thanks!
V
V
Original Message
> From:
(USANYS)
> Sent: Friday, December 20, 2019 12:48 PM
> To:
(USANYS)
i
(USANYS)
> Subject: RE: Nycha
>
> The team has been working to set up a meeting with the EPA representative to drill down on those issues -
because of the holidays, it looks like that will take place on either January 3 or 6.
>
>
Original Message
> From:
(USANYS)
> Sent: Thursday, December 19, 2019 6:01 PM
> To:
(USANYS)
i
(USANYS)
> Subject: Nycha
V
> Any update? Team was drilling into EPA issue and also looking at false statements from the interview.
>
> Sent from my iPhone
EFTA00031585


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=== Page 1 ===
From:
(USANYS)"
To:
USANYS)"
Subject: RE: final meeting before summer!
Date: Mon, 03 May 2021 20:40:25 +0000
Attachments: 2021.04.27_Order_re_Rule_17_subpoenas.pdf
From:
USANYS)
Sent: Monday, May 3, 2021 4:29 PM
To:
(USANYS)
Subject: RE: final meeting before summer!
Nice. If you have it handy, can you send it (or I can ask Lara)?
From:
(USANYS)
Sent: Monday, May 3, 2021 4:28 PM
To:
(USANYS)
Subject: RE: final meeting before summer!
Good. We also recently got a strong opinion from AJN in Maxwell on a motion to quash a Rule 17 subpoena.
From:
USANYS)
Sent: Monday, May 3, 2021 4:16 PM
To:
(USANYS)
Subject: RE: final meeting before summer!
Yes. I weighed in, strongly, about this.
From:
(USANYS)
Sent: Monday, May 3, 2021 4:03 PM
To:
(USANYS)
Subject: RE: final meeting before summer!
Yes, thanks. Glad to see some of our discussion in the bullets below.
From:
Sent: Monday, May 3, 2021 3:59 PM
To:
(USANYS)
Subject: FW: final meeting before summer!
FYI, as discussed some time ago.
From: Marshall L. Miller
Sent: Monday, May 3, 2021 3:45 PM
To: Jenna Dabbs
Subject: final meeting before summer!
All,
EFTA00031694

=== Page 2 ===
I am looking forward to tomorrow's White Collar Crime Committee meeting. Hard to believe it will be our last meeting
before the summer.
Upcoming Events
We'll begin the meeting by discussing two exciting events scheduled for the fall: (1) the International Symposium, which
will take place on November 29-30, 2021, and (2) the panel event featuring authors of prominent books on white collar
crime, which is calendared for September 13, 2021. Although these events aren't for a few months, given the summer
break, we'll spend a few minutes discussing tomorrow.
Speaker
During the second half of the meeting, we will be joined by Ken Blanco. Ken served for many years as a Deputy Assistant
Attorney General in the Criminal Division, after service as an AUSA in the Southern District of Florida. After a stint as
Acting Assistant Attorney General for the Criminal Division, Ken joined the Treasury Department's Financial Crimes
Enforcement Network (FinCEN) as its Director. Ken recently left the government to join Citi as Chief Compliance Officer of
its newly created financial crimes unit.
Rule 17 Project
The bulk of the meeting will involve a continuation of our discussion of the Rule 17 advocacy project. Since our last
meeting, the working group and I have engaged in productive dialogue with the federal defenders and the federal
prosecutors on our committee. Based on those conversations, we propose striking the "other than the victim" language
we had proposed adding to Rule 17(c), which, in our initial proposal read "After a complaint, indictment, or information is
filed, a subpoena requiring the production of personal or confidential information about an individual (non-corporate)
victim may be served on a third party, other than the victim, only by court order." Striking the "other than the victim"
language is intended to address concerns from both the Government (about victim safety) and from the Federal
Defenders' liaison to the Rules Committee. In addition, we have also tweaked the cover letter to the Rules Committee to
address these concerns, to emphasize that our proposal is intended to reduce ambiguity in the Rule as currently drafted,
and to emphasize the fact that, without meaningful subpoena power, many criminal defendants are effectively limited to
building their defense around information gathered and provided by the Government and are severely constrained in
building their own affirmative defenses to meet the Government's allegations.
Both groups provided feedback (all in their individual capacities and not on behalf of their organizations), which we
summarize below and hope to discuss tomorrow:
The proposed revisions actually increase the authority of prosecutors by allowing them to more easily use trial
subpoenas to obtain documents from third parties in advance of trial.
Permitting subpoenas without judicial "gate-keeping" could spark backlash to the proposal.
The Committee should consider revisions to Rule 17(b), which requires court approval of subpoenas for "named
witnesses" where the defendant can't pay witness fees - a requirement that is logistically challenging and only
applicable to indigent defendants.
The letter overstates equity arguments in describing the Government's access to more powerful investigative tools
because: (i) the Government must satisfy a very high burden and (ii) the Government is constrained by Federal Rule
of Criminal Procedure 6, the Privacy Act, and Department of Justice Policy with respect to the information it may
subpoena and how that information may be used.
The letter overstates the flaws of the Nixon standard, since the Government's robust discovery obligations
adequately enable a defendant to understand the strengths and weaknesses of a case against him.
Significantly expanding a defendant's Rule 17 subpoena capabilities may negatively influence the willingness of
victims and witnesses to cooperate, and motions to quash provide an insufficient remedy to address this issue.
The letter offers an inadequate rationale for limiting court approval to subpoenas regarding victims.
We hope to reach consensus on if/how to address the feedback above as well as on any remaining open issues. Ideally,
the working group-with the Committee's approval-will then finalize and submit the proposal over the coming weeks. I
have once again attached the latest version of the revised rule proposal (in clean and redlined versions), as well as the
draft letter to the Advisory Committee on Criminal Rules that the working group has put together.
EFTA00031695

=== Page 3 ===
As always, please do not hesitate to reach out with any questions or comments regarding anything related to the
Committee.
Best regards,
Marshall
Marshall L. Miller I Kaplan Hecker & Fink LLP
350 Fifth Avenue I Suite 7110
New York, New York 10118
(W)
(M)
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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=== Page 1 ===
From:
"
)"
To:
I"
Subject: FW: Shortened talking points
Date: Wed, 24 Jun 2020 19:46:44 +0000
Attachments: Wall_Talking_Points.v3.docx; Global_Energy_Producers_-_Talking_Points.v3.docx;
Jeffrey_Epstein_Co-Conspirators_Talking_Points.v3.docx;
AOC_Investigation_Talking_Points.v2.docx;The_Presidential_Coalition_- -
_Talking_Pointsv3.docx; NRA_Talking_Points.v2.docx
With apologies is this means double work, could you possibly substitute these revised talking points for the earlier
versions in
binder? I can flag where they go if it's not obvious.
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From:
To:
Subject: RE: good morning
Date: Mon, 06 Jul 2020 14:32:30 +0000
Thanks,
All is quiet on my end. We are having a call with
today at 1:15 to discuss Epstein trust-
related matters.
I was thinking about you this morning and hoping that your departure date would not be too soon.
How was your weekend?
Original Message
From
Sent: Monday, July 06, 2020 10:24 AM
To:
Subject: good morning
Good morning. I hope that you had a nice weekend - and were able to take a break from running(!). Any news
of note? None on my end. I'm hoping to speak with
today to sort out the logistics of my departure.
And more stuff along those lines.
Sent from my iPhone
EFTA00031552


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein 6(e) Order
Date: Fri, 20 Dec 2019 20:03:52 +0000
Thanks!
From:
(USANYS)
Sent: Friday, December 20, 2019 12:29 PM
To:
(USANYS)
is
is
(USANYS)
is
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein 6(e) Order
Judge Cote signed the 6(e) order, attached.
Note: anything we send to John Langbein has to comply with EOUSA secure shipping protocols (speak to
)
or EOUSA electronic encryption protocols (speak to IT services). We would look very bad if
any of this ended up someplace it shouldn't. Also give Langbein the necessary cautions.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
Event: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Start Date: 2020-04-03 15:00:00 +0000
End Date: 2020-04-03 16:00:00 +0000
Organizer:
(USAVI)
Location: Conference Line Call-In (see below)
Class: X-PERSONAL
Date Created: 2020-04-02 12:28:26 +0000
Date Modified: 2020-04-02 12:28:26 +0000
Priority: 5
DTSTAMP: 2020-04-02 12:03:06 +0000
Attendee:
(USAVI)
i
(USANYS)
i
(USANYS)
Alarm: Display the following message 4h before start
Reminder
Toll Free Number: 866-421-2611
Passcode: 1950230#
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Shortened talking points
Date: Wed, 24 Jun 2020 19:54:39 +0000
Attachments: AS_AG_Briefing_Book_(as_of_6.24.20)v4.pdf
Here's the updated digital briefing book. Thanks.
From:
Sent: Wednesday, June 24, 2020 3:46 PM
To:
Subject: RE: Shortened talking points
Great point. Moving forward, we will. l'll make sure these make it into your binder and that you have pdfs of the most
recent versions in an updated portfolio.
From:
Sent: Wednesday, June 24, 2020 3:44 PM
To:
Subject: FW: Shortened talking points
Here are revised talking points.
FYI, we should give direction at outside that TP's need to be short and crisp, esp for meeting with AG where time is of the
essence.
From:
(
Sent: Wednesday, June 24, 2020 3:04 PM
To:
)
Cc:
Subject: Shortened talking points
- as requested, I've chopped all the talking points to a page or less (except GEP, which is still much shorter).
Happy to further refine.
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=== Page 1 ===
From: "Westlaw@westlaw.com" <Westlaw@westlaw.com>
To:
Subject: [EXTERNAL] TITLE 18 INSIDER TRADING
Date: Tue, 30 Nov 2021 05:10:59 +0000
Attachments: TITLE_18_INSIDER_TRADING.pdf
sent you content from Westlaw Edge.
Please see the attached file.
Item: TITLE 18 INSIDER TRADING
Citation: 130 Yale L.J. 1828
Sent On; Monday November 29, 2021
Sent By:
Client ID: DOJ
Note:
Westlaw © 2021 Thomson Reuters. No claim to original U.S. Government Works.
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=== Page 1 ===
From:
To:
Subject: Automatic reply: Epstein Case A Turning Point In Prosecutorial Accountability?
Date: Tue, 12 Feb 2019 11:29:41 +0000
Importance: Normal
I am currently on trial.
For emergencies requiring immediate assistance, please contact AUSA
at
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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
(USANYS)"
(USANYS)"
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Date: Tue, 08 Dec 2020 17:45:50 +0000
Attachments: 2020.12.08_AJN_Order_re_MDC.pdf
Best,
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:NYSD_ECF_Pool@nysd.uscourts.gov <NYSD_ECF_Pool@nysd.uscourts.gov>
Sent: Tuesday, December 8, 2020 12:03 PM
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=== Page 2 ===
To: CourtMail@nysd.uscourts.gov
Subject: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
e-mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.
U.S. District Court
Southern District of New York
Notice of Electronic Filing
The following transaction was entered on 12/8/2020 at 12:02 PM EST and filed on 12/8/2020
Case Name:
USA V. Maxwell
Case Number:
1:20-cr-00330-AJN
Filer:
Document Number: 92
Docket Text:
ORDER as to Ghislaine Maxwell: On December 4, 2020, the Court received a letter from MDC
legal counsel responding to the concerns that the Defendant raised in her November 24, 2020
letter. See Dkt. Nos. 75, 88; see also Dkt. No. 78. The Defendant responded to the MDC legal
counsel's letter on December 7, 2020, reiterating her request that the Court summon Warden
Heriberto Tellez to personally respond to questions from the Court regarding the Defendant's
conditions of confinement. See Dkt. No. 91. Having carefully reviewed the parties' submissions,
along with the MDC legal counsel's December 4, 2020 letter, the Court DENIES the Defendant's
request to summon the Warden to personally appear and respond to questions. This resolves
Dkt. No. 75. Notwithstanding this, as originally provided in Dkt. No. 49, the Government shall
continue to submit written status updates detailing any material changes to the conditions of
Ms. Maxwell's confinement, with particular emphasis on her access to legal materials,
including legal mail and email, and her ability to communicate with defense counsel. The
updates shall also include information on the frequency of searches of the Defendant. The
Court hereby ORDERS the Government to submit these written updates every 60 days.
Furthermore, the Government shall take all necessary steps to ensure that the Defendant
continues to receive adequate access to her legal materials and her ability to communicate
with defense counsel. (Signed by Judge
J. Nathan on 12/8/2020) (ap)
1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
Jeffrey S. Pagliuca jpagliuca@hmflaw.com, nsimmons@hmflaw.com
Laura A. Menninger Imenninger@hmflaw.com, alundberg@hmflaw.com, nsimmons@hmflaw.com
Bobbi C Sternheim bc@sternheimlaw.com, bcsternheim@mac.com, ecf@sternheimlaw.com
Christian R. Everdell ceverdell@cohengresser.com, autodocket@cohengresser.com
Mark Stewart Cohen mcohen@cohengresser.com, Mark-Cohen-1234@ecf.pacerpro.com,
autodocket@cohengresser.com, managingclerksoffice@cohengresser.com
CaseView.ECF@usdoj.gov,
EFTA00030687

=== Page 3 ===
USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov,
USANYS.ECF@USDOJ.GOV
1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1008691343 [Date=12/8/2020] [FileNumber=25049471-
0]
[4e2f0541bc896e461bd043db68fe94f5538c87c7f408faa5d11202151b70a7a980
3e9613969adcd785259ef1112c8e0ede95ad58040bd30229e0b4eb35d9f3de]]
EFTA00030688


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=== Page 1 ===
From:
]"
To:
Bcc:
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 09 Oct 2020 21:08:11 +0000
Embedded: RE:_Epstein_Maxwell_Upload.msg
Sender:
Subject: RE: Epstein/Maxwell Upload
Message-Id:
<SN5P110MB05593273FF233BAB354E83E1F8080@SN5P110MB0559.NAMP110.PROD.OUTLOOK.COM>
EFTA00030591


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=== Page 1 ===
NEW YORK DEPARTMENT OF STATE
Division of Corporations
Attn: Subpoena Compliance
SUBPOENA RIDER
Please provide any and all copies of Articles of Incorporation and any other information
filed with the STATE OF NEW YORK in regard to the incorporation of the following
companies:
NINE EAST 71ST STREET CORPORATION
575 Lexington Avenue, 4th Floor, New York,
NY 10022
301 East 66th Street, 10F, New York, NY
10065
MAPLE, INC
9100 Havensight, Port of Sales, Suite 15/16,
St Thomas 00802 Virgin Islands, U.S.
Records should be forwarded to:
Federal Bureau of Investigation
Attn:
New York, NY 10278
Phone:
Email:
(Serve via email to: ALBANY DIVISION, Attn: Carmelo Burgos)
EFTA00030236


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:23:37 +0000
Inline-Images: image001.png
Congratulations! I'm very proud of you guys.
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
EFTA00031476

=== Page 2 ===
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
EFTA00031477

=== Page 3 ===
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00031478


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=== Page 1 ===
Event: Accepted: Call re: Epstein FOIA
Start Date: 2021-03-19 13:00:00 +0000
End Date: 2021-03-19 13:30:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2021-03-11 23:41:26 +0000
Date Modified: 2021-03-11 23:41:26 +0000
Priority: 5
DTSTAMP: 2021-03-11 21:07:25 +0000
Attendee:
)
EFTA00030079


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=== Page 1 ===
Good afternoon, my name is Geoffrey Berman, I am the U.S. Attorney for the Southern District
of New York. Almost exactly one year ago today, I announced a two-count indictment of Jeffrey
Epstein by this Office for sexually abusing young girls.
A lot has changed since then.
Rather than face criminal prosecution, Epstein chose - as he so often did - to act selfishly, by
taking his own life just mere feet from here in the shadow of the very building where we
announced his indictment. Immediately after Epstein committed his final act of cowardice, I
announced that the search for those who enabled his hideous conduct would not end. And it
has not.
Epstein's suicide could not extinguish the voices or resolve of his victims, he only emboldened
them. Rather than let him have the final word, they chose to speak. Loudly. And with their help,
I am announcing the indictment of Ghislaine Maxwell, for [enumerate charges and detail her
conduct] for her alleged connection to the sex crimes of Jeffrey Epstein.
This case has been attention-getting and polarizing for so many reasons, the least of which is
that the victims of Epstein and Maxwell refuse to remain in the shadows, and their courage and
determination have been critical in bringing today's charges. These women have found their
voice and I hope serve as examples for other victims of abuse to come forward. Your voices are
being heard and you no longer need to remain in the shadows of abuse. These women deserve
respect, empathy, compassion, and most of all, justice.
As we stand in front of the historic federal courthouse, I'll conclude by saying that today's
charges remind us: no matter how wealthy, powerful, or well-connected you may be, justice is
blind in the eyes of the law, and if you abuse young women in this District, you will face justice.
EFTA00029807


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=== Page 1 ===
From: "Weingarten, Reid"
To:
)"
Subject: Re: U.S. V. Epstein, 19 Cr. 490
Date: Mon, 08 Jul 2019 10:00:37 +0000
Thanks see you in the morning
Sent from my iPhone
On Jul 7, 2019, at 11:16 PM,
)
wrote:
Reid,
I understand you'll also be appearing for Mr. Epstein tomorrow, so I wanted to send the full contact information for our
team, as we did previously for Marty. As the case goes forward, please feel free to reach out to any of us at the below
contacts, and we'll see you in the morning.
(office)
(cell)
(office)
(cell)
(office)
(cell)
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030168


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
)"
Subject: 3500
Date: Tue, 30 Nov 2021 00:03:10 +0000
Embedded: FW:_IEXTERNAL]_FBI_Still_Needing_Tips_Regarding_Jeffrey_Epstein__Ghislaine_Maxw
ell?.msg
Could you please add this to NTW 3500? In addition, hard copy 3500 for
is on my desk when you have a minute. We
should send that out tonight. Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031728


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: RE: NT 3500
Date: Sun, 11 Apr 2021 03:06:59 +0000
Hi
Below are the changes that are needed for my section:
Please delete the following folders:
is the same person as
would you please move everything from the
folder into the
folder?
Please merge everything in the
folder into the
folder
is the same persons as
who is a testifying witness. Would you please move the
entire
folder into the
oflder?
With those changes, my section (101 through 196) is ready to go.
Thanks so much,
From:
Sent: Saturday, April 10, 2021 12:33 AM
To:
Cc:
is
(USANYS)
Subject: NT 3500
Hi
Thanks for all your work on this project. I few things from my review, though I'll likely send some additional things
tomorrow:
The
folder contains just one report, and I think that goes in the
folder instead.
Please move it and delete his folder. Same thing for the
folder.
are the same person and the folders can be merged under the name
EFTA00031349

=== Page 2 ===
is the same person a
a potential testifying witness. Could you please move those
materials and delete the folder?
The stuff in the
folder should actually go in the
folder, and you can delete
the one fo
once the stuff is moved over.
In the
folder, there's a transcript of a deposition of Mark Epstein. Could you please move that into a
new, NTW folder for him?
, and
: could you please
move these to the not-a-witness folder you created? We'll deal with the contents later, but not in the context of
the NTW production.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031350


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=== Page 1 ===
From:
(USANYS)"
To:
)"
:
Subject: Automatic reply: Epstein VNS
Date: Thu, 30 Jul 2020 16:20:18 +0000
I am on annual leave.
For transportation please call or email
.
If you need to speak to me you
can try my cell phone.
Thank you,
Victim Witness Coordinator
EFTA00030797


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
Date: Thu, 30 Jul 2020 18:28:27 +0000
Inline-Images: image001.jpg; image002.png; image003.png
No problem
From:
Sent: Thursday, July 30, 2020 2:28 PM
To:
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
If you wouldn't mind, thank you!!
From:
Sent: Thursday, July 30, 2020 14:27
To:
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
Need me to send the WebEx invite?
From:
Sent: Thursday, July 30, 2020 2:22 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
i
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
Great, thanks very much.
From: Jill Greenfield
Sent: Thursday, July 30, 2020 14:09
To:
Cc: Kyle Phillips
>; Louise Scott
is
^
is
Subject: Re: SDNY investigation [FFW-DOCS.FID6003375]
That works for me. Speak then.
Jill Greenfield
Partner
D:
M:
Click here for information relating to Covid-19 business impacts
EFTA00031211

=== Page 2 ===
f
in
Sent from my iPhone
On 30 Jul 2020, at 19:05,
-
wrote:
Jill,
Thanks very much for being in touch, and we would welcome the opportunity to follow up on those topics. Would it
work to schedule a call for Wednesday, August 12? We could do 4:00 p.m. London time (11:00 a.m. for us), if that would
be convenient for you? And we can schedule it as a WebEx so we can see each other, if that's alright, or do it as a call if
you prefer.
thanks,
From: Jill Greenfield
Sent: Thursday, July 30, 2020 12:51
To:
>; Kyle Phillips
Cc: Louise Scott
is
is
Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
Thanks
I have been in discussions with my client and we ought to be in a position to provide you with more information in the
categories suggested. I am away next week but shall we schedule a call on my return, the week commencing 10th
August?
Kind regards,
Jill
Jill Greenfield
Partner
D:
M:
Click here for information relating to Covid-19 business impacts
<image004.jpg>
<image002.png><image003.png>
From:
)
Sent: Monday, July 20, 2020 4:19 PM
To: Jill Greenfield
>; Kyle Phillips
Cc: Louise Scott
is
is
EFTA00031212

=== Page 3 ===
Subject: RE: SDNY investigation
Jill, Kyle,
Following up on our recent WebEx discussion, and with apologies for the slight delay, we wanted to get you a list of
initial categories of question that we think might assist in your discussion with your client, with the goal of then doing an
attorney proffer, or attorney summary, and discussing possible next steps.
We note that the below questions are simply general thoughts and suggestions-some may not need to be asked at all,
others may prompt follow-up from you in the moment, etc. In any interviews with us, we ordinarily are guided both by
the comfort level and the narrative of the witness, but we hope these give you a sense of what we would be interested
in. We also note that we included questions about sexual contact because it is our very general understanding from you
that abuse occurred, but we do not make any presumptions about what happened, if anything, separate from what your
client recalls. On that note, as we've discussed, but to reiterate, if there are any questions or topics your client is
uncomfortable addressing, there will be no pressure from us to do so, including at this early stage.
With those caveats, possible questions are below, and please let us know if it would be useful for us to chat again before
you talk with your client, or otherwise please let us know when it would next be appropriate to check in.
Questions / topics:
1) General background queries: Where did you grow up? How far did you go in school? What is your date of birth?
How generally would you describe your upbringing and early professional life?
2) How did you initially meet Ghislaine Maxwell and Jeffrey Epstein, and how old were you at that time? What was the
nature of your work with them, and did the role change over time? How long did you work for Maxwell and/or
Epstein?
3) In general, what kinds of tasks did you perform for Maxwell or Epstein, and in what locations? Did you travel with
either of them? When you weren't traveling with them, where did you reside? Did you ever reside with Maxwell or
Epstein? If so, where - in what locations and at which properties?
4) Did there come a time when Epstein and/or Maxwell engaged in sexual contact with you? If so, how did that
happen the first time? Were there sexualized discussions or was there sexualized conduct leading up to any first
incident?
5) Were there other instances when you experienced sexual abuse or sexual contact while working for Maxwell? If so,
how did those incidents occur? Did they occur with Epstein alone, or was Maxwell ever directly involved in the
sexual contact? Did Maxwell ever observe, or was she present for, sexual contact that she herself was not
participating in? Were any other individuals present or participating?
6) Were you aware of any other girls or women who were subject to sexual abuse or contact by Epstein and/or
Maxwell, and if so, who? Did you ever see Epstein or Maxwell involved in sexual or other intimate contact with
other girls you believed or suspected may have been under the age of 18? And if so, under what circumstances
(when, where, etc.)?
7) How did your interactions with Epstein and Maxwell end? Did either of them contact you or attempt to contact you
when Epstein was under investigation in 2006-08? Did either of them contact you or attempt to contact you during
the New York investigation in 2018-20? If so, what was the nature of that contact? When is the last time you spoke
with or otherwise interacted with Epstein and/or Maxwell?
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00031213

=== Page 4 ===
Fieldfisher, Riverbank House,
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,
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.
EFTA00031214


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=== Page 1 ===
From:
"
)"
To:
)"
,
)"
Subject: Gov't reply to Epstein bail motion due
Date: Mon, 08 Jul 2019 20:42:05 +0000
Importance: Normal
Attachments: unnamed
EFTA00030823


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Requests
Date: Wed, 24 Jun 2020 13:07:30 +0000
Attachments: Hot_lists.pdf; Noel_Acknowledegment.pdf; Noel_Training_Record.pdf
fyi
From:
Sent: Wednesday, June 24, 2020 8:44 AM
To:
Cc:
Subject: RE: Requests
Here are a few more things from your request. I have been unable to locate any watch calls or SROs from the requested
time frame. I will continue to look for those documents. I have been told SROs were likely not completed during that time
and also that most of the Control Center paperwork (originals), to include watch call sheets, were seized by the FBI and/or
OIG shortly after the incident, and therefore are no longer in the institution.
Please let me know if you have any questions or if I can be of any further assistance.
Cody
>>>
06/23/20 3:55 PM
Thank you, my brother!
From:
Sent: Tuesday, June 23, 2020 3:53 PM
To:
Cc:
Subject: Re: Requests
I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email.
Let me know if you have any questions.
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
06/12/20 1:54 PM >>>
Hi Cody:
Hope you and fam have been well, as well as MCC staff.
EFTA00030480

=== Page 2 ===
Can you please provide the following information concerning the Epstein suicide investigation:
The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement
forms for Defendant Noel.
The MCC institutional familiarization training outline.
The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations,
including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
The BOP and MCC policy on SHU quarterly training.
The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
All SHU Watch Call Logs completed during Defendant
assignment to the SHU post which began on June 26,
2019.
All SHU Control Center Logs completed during Defendant
assignment to the SHU post which began on
June 26, 2019.
All SHU Operations Lieutenant Log Books completed during Defendant
assignment to the SHU post which
began on June 26, 2019.
All High Risk Lists reviewed during weekly SHU meetings during Defendant
assignment to the SHU post
which began on June 26, 2019.
All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant
assignment to the SHU
post which began on June 26, 2019.
Many thx!
EFTA00030481


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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 14:42:58 +0000
Date Modified: 2020-05-21 14:42:58 +0000
Priority: 5
DTSTAMP: 2020-05-21 14:03:00 +0000
Attendee:
l
EFTA00031831


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-770 United States of America V. Maxwell "Motion FILED for bail"
Date: Mon, 17 May 2021 20:50:01 +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 05/17/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
MOTION, for bail, on behalf of Appellant Ghislaine Maxwell in 21-770, 21-58, FILED. Service date 05/17/2021
by CM/ECF. [3102450] [21-770, 21-58]
Notice will be electronically mailed to:
Ms. Bobbi C. Sternheim, -: bc@sternheimlaw.com, bc@sternheimlaw.com, ecf@sternheimlaw.com
Assistant U.S. Attorney:
Assistant U.S. Attorney:
, Assistant U.S. Attorney:
David Oscar Markus, -: dmarkus@markuslaw.com, caguero@markuslaw.com
Ms. Khadijah Y Young, Deputy Clerk: khadijah_young@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Ms. Khadijah Y Young, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion FILED
Original Filename: Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-0]
[af9aab28891e80a21dee810d54129a886570637c738ee09dc616ff56110a0f1aef0897141dbcec842505547dc49999
11dd5d8fc8da383fbe04f509071ec0dad8]]
EFTA00029697

=== Page 2 ===
Document Description: Supporting Document
Original Filename: Appendix to the Renewed Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-1]
[bfd5d5123fc8fc9fca32aecd0dbde6bcfb337f880c0f0bde611f6521f7e4147a1afa4cae33bb83a940a70a8bc2c59239
2b151424f9d6cadb6b194593aaaa12ee]]
EFTA00029698


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=== Page 1 ===
THEIR
This certificate is
awarded to
Michael A. Thomas
in recognition of Twenty Years
of service in the
Government of the
United States of America.
June 20th, 2019
Julye
L. N' Diaye, Warden
EFTA00031444


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=== Page 1 ===
From
To
Subject: RE: grand jury
Date: Tue, 23 Jun 2020 15:07:07 +0000
This is perfect-thanks so much! Really appreciate the help. Hope you're doing well!
From:
Sent: Tuesday, June 23, 2020 10:34 AM
To:
Subject: RE: grand jury
Hey - here's the PowerPoint with everything from your two emails. For the excerpts, I was a bit unsure because there
were a lot of objections which I chose to leave in out of caution. Let me know if I should be going back and making
changes.
From:
Sent: Monday, June 22, 2020 10:32 PM
To:
Subject: RE: grand jury
Will,
Apologies for piling on, but if you could please also make slides that have the following excerpts of the attached
deposition testimony, that would be a huge help as well:
The cover page of both days of testimony (so the caption and date shows)
The following five excerpts (I think you should be able to just control-F to locate):
1)
Q.
Did Jeffrey Epstein have a scheme to recruit underage girls
for sexual massages? If you know.
A.
I don't know what you' re talking about.
2)
Q.
List all the people under the age of 18 that you interacted
with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with, other than
obviously
who was 17 at this point.
3)
Q: Were you aware of the presence of sex toys or devices used in
sexual activities in Mr. Epstein's Palm Beach house?
EFTA00031836

=== Page 2 ===
A: No, not that I recall
Q.
Do you know whether Mr. Epstein possessed sex toys or
devices used in sexual activities?
A.
No.
4)
Q.
Other than yourself and the blond and brunette that you have
identified as having been involved in three-way sexual
activities, with whom did Mr. Epstein have sexual
activities?
A.
I wasn't aware that he was having sexual activities with
anyone when I was with him other than myself.
Q.
I want to be sure that I'm clear. Is it your testimony that
in the 1990s and 2000s, you were not aware that Mr. Epstein
was having sexual activities with anyone other than yourself
and the blond and brunette on those few occasions when they
were involved with you?
A.
That is my testimony, that is correct.
5)
Q.
Is it your testimony that you've never given anybody a
massage?
A.
I have not given anyone a massage.
Q.
You never gave Mr. Epstein a massage, is that your
testimony?
A.
That is my testimony.
Q.
You never gave [Minor Victim-2] a massage is your testimony?
A.
I never gave [Minor Victim-2] a massage.
Thank you! Very much appreciated.
From:
Sent: Monday, June 22, 2020 7:17 PM
To:
Subject: RE: grand jury
EFTA00031837

=== Page 3 ===
Fantastic, thanks! Attached is a sample slide for a model. All the slides will be this same format-the document is an
excerpt from flight records. The records are attached - could you please make slides excerpting the records (and flagging
the date) for the following flight dates:
November 11, 1996.
May 9, 1997
May 3, 1998
August 18, 1994
August 20, 1994
January 3, 1995
February 12, 1995
No need for any introductory material - I'll just drag these slides into my presentation once you prep them. Thanks a ton!
This is a big help.
From:
Sent: Monday, June 22, 2020 7:10 PM
To:
Subject: Re: grand jury
Hi
l'll be sure to have time tomorrow. Just let me know what you need and I can handle it.
Will
On Jun 22, 2020, at 6:50 PM,
wrote:
Hey
I'm working on a grand jury presentation on a compressed timeframe, and was hoping you might be able to help put
together a few slides. I'm handling the rest of the slides, but if you could possibly make about seven slides to drop in,
that would be a big help - I need to add a few that will all be the same format. Any chance you have time tomorrow?
Thanks!
Assistant United States Attorney
Southern District of New York
New York. NY 10007
EFTA00031838


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=== Page 1 ===
From:
To: Stan Pottinger
Subject: docketed version
Date: Fri, 12 Jul 2019 22:56:06 +0000
Importance: Normal
Attachments: 2019-07-12,_JE,_government_opposition_to_bail_motion_(with_exhibits).pdf
Assistant U.S. Attorney
Southern District of New York
EFTA00030204


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: FW: Epstein search warrant documents
Date: Mon, 01 Jun 2020 20:10:17 +0000
Attachments: EpsteinNYEvidence.xlsx
I confess I'm having a hard time tracking the updates to this - but in particular,
do you now have what you need
for the updated SW? Or still no? Thanks for helping with this as you can probably tell from my emails today, I'm going
a little nuts just trying to drag the FBI toward any usefulness with the financials and electronics
From:
Sent: Friday, May 29, 2020 12:53
To:
is
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
EFTA00030665

=== Page 2 ===
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
Sent: Thursday, May 14, 2020 15:54
To:
)
is
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
is
Cc:
is
)
is
EFTA00030666

=== Page 3 ===
is
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
Sent: Tuesday, May 12, 2020 13:03
To:
is
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
EFTA00030667

=== Page 4 ===
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
Sent: Tuesday, May 12, 2020 11:30
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
Sent: Tuesday, May 12, 2020 11:11
To:
is
Cc:
is
-
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
EFTA00030668

=== Page 5 ===
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
is
(USANYS)
>;
is
(USANYS)
Cc:
is
>;
is
i
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
)
V.
(USANYS)
Cc:
is
>;
EFTA00030669

=== Page 6 ===
is
is
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks- it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
)
is
V.
(USANYS)
Cc:
in
is
is
is
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
EFTA00030670

=== Page 7 ===
thanks,
From:
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
>;
is
(USANYS)
Cc:
is
)
>;
is
is
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
V.
is
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
EFTA00030671

=== Page 8 ===
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
is
(USANYS)
is
is
(USANYS)
Cc:
>;
V.
i
is
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
EFTA00030672

=== Page 9 ===
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
V.
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
i
is
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
>;
is
(USANYS)
Cc:
is
is
is
is
EFTA00030673

=== Page 10 ===
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
in
is
i
>;
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
V.
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
EFTA00030674

=== Page 11 ===
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
EFTA00030675

=== Page 12 ===
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00030676


c1: EFTA00031025
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031025.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
V.
FEDERAL BUREAU OF PRISONS,
Defendant.
DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
1.
I am Counsel to the Acting United States Attorney in the United States Attorney's
Office for the Southern District of New York ("USAO-SDNY"). I have served in this capacity
since June 2020. Prior to my current role, I served as Deputy Chief and then Chief of the Public
Corruption Unit in the USAO-SDNY from July 2017 and as an Assistant United States Attorney
from January 2011. I supervised the Noel prosecution directly in my prior role as Chief of the
Public Corruption Unit, and I play a supervisory role over both the Noel and Tartaglione
prosecutions in my current role as Counsel to the Acting United States Attorney.
2.
I am familiar with the Freedom of Information Act requests filed by the New
York Times Company (the "FOIA Requests") that are the subject of this case, which seek
records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center
("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of
Prisons ("BOP") has withheld pursuant to exemptions 5, 6, 7(A), 7(C), 7(E), and 7(F) of FOIA, 5
U.S.C. § 552(b)(5)-(7). In addition, I am familiar with the proceedings in United States of
1
EFTA00031025

=== Page 2 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 2 of 13
America V. Noel, 19-CR-830 (AT), and United States of America V. Tartaglione, 16-CR-832
(KMK). True and correct copies of the Indictment filed in Noel on November 19, 2019 (the
"Noel Indictment"), and the Superseding Indictment filed in Tartaglione on April 16, 2019 (the
"Tartaglione Indictment"), are attached hereto as Exhibits A and B, respectively. The statements
contained in this declaration are based on my personal knowledge, documents maintained in the
files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution
teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith.
3.
I submit this declaration in support of BOP's motion for summary judgment in
this case.
The Prosecution of Jeffrey Epstein
4.
On July 2, 2019, Jeffrey Epstein was charged with one count of conspiracy to
commit sex trafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in
violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. On July 6, 2019, Epstein was arrested and
thereafter incarcerated at the MCC until his death.
5.
On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU") at
the MCC due to, among other things, a risk of suicidality and safety concerns relating to housing
him with the MCC's general population. On July 18, 2019, a bond hearing as to Epstein was
held before the Honorable Richard M. Berman, after which the Court granted the government's
motion for remand and denied Epstein's motion for pretrial release. See Noel Indictment I 10.
6.
On July 23, 2019, MCC officers responded to an emergency call and found
Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment
I 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel
case, was one of the MCC officials who responded to this incident. See id. Epstein was
subsequently transferred out of the SHU, placed on suicide watch for 24 hours, and then
2
EFTA00031026

=== Page 3 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 3 of 13
transferred to psychological observation, a different status in a different location within MCC's
hospital ward, until July 30, 2019. On July 30, 2019, Epstein was transferred back to the SHU.
See id. II 11-13.
7.
On August 10, 2019, Epstein was found in his cell, not responsive and with a
noose around his neck. See id. I 26. He was transferred to a local hospital where he was
declared dead shortly thereafter. See id. I 27. The Office of the Chief Medical Examiner of the
City of New York conducted an autopsy and determined that Epstein had committed suicide by
hanging himself. See id.
8.
On August 29, 2019, following a public hearing on August 27, 2019, Judge
Berman entered an order of nolle prosequi against Epstein. See Nolle Prosequi, Dkt. No. 52,
United States V. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.).
The Prosecution of Tova Noel and Michael Thomas
9.
As alleged in the Noel Indictment, Thomas and Tova Noel were correctional
officers on duty at the SHU on August 9-10, 2019, the night of Epstein's death. See Noel
Indictment II 3-4. On that night, Noel and Thomas repeatedly failed to perform mandated
counts of prisoners under their watch, including Epstein. To conceal this failure, they repeatedly
signed false certifications attesting to having conducted multiple counts of inmates, when, in
truth, they had not conducted such counts. See id. II 15-24. On November 19, 2019, Noel and
Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United
States and to make or use a false writing or document, in violation of Title 18, United States
Code, Section 371; and five counts as to Noel and three counts as to Thomas of making or using
a false writing or document, in violation of Title 18, United States Code, Sections 1001(a)(3) and
(2). Noel Indictment I 28-40. The Noel case is pending before the Honorable Analisa Torres.
Trial has been scheduled to begin on January 4, 2021.
3
EFTA00031027

=== Page 4 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 4 of 13
The Prosecution and Incarceration of Nicholas Tartaglione
10.
In a superseding indictment filed on April 16, 2019, Nicholas Tartaglione was
charged with one count of conspiracy to distribute narcotics, in violation of Title 21, United
States Code, Section 846; four counts of intentional killing in furtherance of a drug trafficking
crime, in violation of Title 21, United States Code, Section 848(e)(1)(A) and Title 18, United
States Code, Section 2; three counts of murder through the use of a firearm in furtherance of a
drug trafficking crime, in violation of Title 18, United States Code, Sections 924(j) and 2; one
count of conspiracy to commit kidnapping, in violation of Title 18, United State Code, Section
1201; four counts of kidnapping resulting in death, in violation of Title 18, United States Code,
Sections 1201(a)(1) and 2; and four counts of using a facility of interstate commerce to commit a
crime of violence in violation of Title 18, United States Code, Sections 1952 and 2. These
charges arise from the April 2016 murders of Martin Luna, Miguel Luna, Urbano Santiago, and
Hector Gutierrez. On April 19, 2019, USAO-SDNY filed a Notice of Intent to Seek the Death
Penalty against Tartaglione. The Tartaglione case is pending before the Honorable Kenneth M.
Karas. No trial date has been set.
11.
Tartaglione has been detained since he was arrested on December 19, 2016. For
certain periods of his detention, including in July 2019, Tartaglione was housed at the MCC. In
early July 2019, Tartaglione was transferred to the MCC's SHU. For a time, including on July
23, 2019, Tartaglione was housed in the same SHU cell as Jeffrey Epstein.
Records Withheld from Disclosure Pursuant to FOIA Exemption 7(A) on
Account of Likely Interference with Noel
12.
5 U.S.C. § 522 (b)(7)(A) ("Exemption 7(A)") exempts from disclosure "records
or information compiled for law enforcement purposes, but only to the extent that the production
4
EFTA00031028

=== Page 5 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 5 of 13
of such law enforcement records or information
could reasonably be expected to interfere
with enforcement proceedings
"
13.
I and the prosecutors responsible for the Noel prosecution have reviewed each of
the records responsive to the FOIA requests withheld in full or in part under Exemption 7(A),
including those reflected on the index prepared by BOP and attached to the declaration of Kara
Christenson (the "BOP index"). All of these records fall within the scope of Exemption 7(A).
14.
Public disclosure of the records withheld under Exemption 7(A) could reasonably
be expected to interfere with the pending prosecutions of Noel and Thomas. These records
include information about which numerous witnesses are expected to testify at trial, include
details that are not publicly known or known to other witnesses, and include information and
documents authored by potential trial witnesses. These records also include potential trial
exhibits, which some or all potential trial witnesses have not seen, and premature disclosure of
those materials could influence witness testimony at trial, or enable witnesses to change or shape
their testimony. Premature disclosure of these records and/or the information contained therein
could reasonably be expected to influence witnesses' potential testimony at trial and/or allow
witnesses to alter their testimony to conform to other evidence.
15.
Further, premature public disclosure of the records withheld under Exemption
7(A) could reasonably be expected to impair the government's (and the defendants') ability to
seat a fair and impartial jury in Noel. The government anticipates that some of the records
withheld under Exemption 7(A) will be entered into evidence as exhibits at trial, and other
records that may not be trial exhibits bear on the contents of potential trial exhibits. Premature
disclosure of these records, or the information contained therein, could influence potential jurors'
understanding of the evidence at trial and the case overall. Similarly, premature disclosure of the
records could prejudice potential jurors for or against the defendants in the Noel action, which
5
EFTA00031029

=== Page 6 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 6 of 13
would also impair the government's (and the defendants') ability to seat a fair and impartial jury.
In addition, as noted above, these records include specific information about which witnesses are
expected to testify at trial, as well as information and documents authored by potential trial
witnesses, such that premature public disclosure could reasonably be expected to influence
potential jurors' perception of the witnesses and the evidence to be presented at trial.
16.
The risks of interference with the Noel proceedings are heightened by the media
coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of
Epstein's death are unfounded. Premature release of the withheld records, particularly if the
records are released in part or without full context, may influence the perception of jurors who
have been exposed to such media coverage of speculation and theories.
Non-Email Records Withheld Pursuant to Exemption 7(A) on
Account of Likely Interference with Noel
17.
The considerations discussed above apply to each of the categories of responsive
non-email records withheld in full or in part by BOP under Exemption 7(A).
18.
First, the government anticipates that MCC staffing records, including overtime
logs and daily assignment rosters for the MCC on July 22, July 23 August 9, and 10, 2019 and
some of the dates in between, will be the subject of witness testimony at the Noel trial. In
addition, the government anticipates that some of these documents will be trial exhibits.
Releasing these materials prematurely could reasonably be expected to influence witnesses'
potential testimony at trial, allow witnesses to alter their testimony to conform to other evidence,
or influence potential jurors' perceptions of witness testimony or evidence.
19.
Second, the government anticipates that reports and memoranda prepared by
BOP, such as the reports, memoranda, photographs, and evidence of Epstein's July 23, 2019
apparent suicide attempt; reports, memoranda, and letters concerning Epstein's August 10, 2019
6
EFTA00031030

=== Page 7 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 7 of 13
suicide and surrounding events; documents in BOP's possession from the New York City Office
of Chief Medical Examiner; and reports and letters concerning MCC's and BOP's response to
Epstein's death, may be trial exhibits, the subject of witness testimony, or were prepared by
witnesses who will testify at trial. Premature disclosure of these materials could reasonably be
expected to influence witnesses' potential testimony at trial, allow witnesses to alter their
testimony to conform to other evidence, or influence potential jurors' perceptions of witness
testimony or evidence. Alternatively, if evidence of Epstein's July 23, 2019 suicide attempt or
August 10, 2019 suicide and surrounding events is excluded from evidence at trial, pre-trial
publication of these materials would risk exposing potential jurors for or against the defendants
in the Noel action on the basis of material they would otherwise not be shown during trial, which
would impair the government's (and the defendants') ability to seat a fair and impartial jury.
20.
Third, the government anticipates that certain medical and psychological records
of Epstein prepared by BOP may be trial exhibits, the subject of witness testimony, and/or were
prepared by witnesses who will testify at trial. Premature disclosure of these records could
influence the testimony of potential witnesses, including by potentially causing them to alter or
confirm their testimony. In addition, premature disclosure of these records could reasonably be
expected to prejudice potential jurors for or against the defendants in the Noel action, which
would impair the government's (and the defendants') ability to seat a fair and impartial jury.
21.
Fourth, the government anticipates that documents related to counts of inmates,
including logs, count slips, and rosters, and other entries in BOP logs for August 9 and 10 may
be trial exhibits, the subject of witness testimony, and/or were prepared by witnesses who will
testify at trial. Premature disclosure of these materials could reasonably be expected to influence
witnesses' potential testimony at trial, allow witnesses to alter their testimony to conform to
other evidence, and/or influence potential jurors' perceptions of witness testimony or evidence.
7
EFTA00031031

=== Page 8 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 8 of 13
22.
Fifth, the government anticipates that an August 8, 2019, review of inmates in the
SHU prepared by BOP may be a trial exhibit, the subject of witness testimony, and/or was
prepared by witnesses who will testify at trial. Premature disclosure of this record could
reasonably be expected to influence witnesses' potential testimony at trial and/or allow witnesses
to alter their testimony to conform to other evidence.
Email Records Withheld Pursuant to Exemption 7(A) on
Account of Likely Interference with Noel
23.
The considerations discussed above also apply to each of the categories of
responsive email documents withheld in full or in part by BOP under Exemption 7(A).
24.
First, emails pertaining to Epstein's July 23, 2019 apparent suicide attempt, his
incarceration prior to his suicide, and his mental health, including emails written by BOP's
Psychology Services, discuss topics and information that the government anticipates may be the
subject of witness testimony at the Noel trial. Their disclosure could influence witness
testimony, including by allowing witnesses to alter their testimony to conform to other evidence,
or influence potential jurors' perceptions of witness testimony or evidence. Alternatively, as
described above, if evidence of Epstein's July 23, 2019 suicide attempt or is excluded from
evidence at trial, pre-trial publication of these materials would risk exposing potential jurors for
or against the defendants in the Noel action on the basis of material they would otherwise not be
shown during trial, which would impair the government's (and the defendants') ability to seat a
fair and impartial jury.
25.
Second, emails relating to Epstein's death, investigations into Epstein's death, the
circumstances of his suicide, and the BOP's response to Epstein's death discuss topics and
information that the government anticipates will be relevant to and/or the subject of witness
testimony at the Noel trial. Their disclosure could influence witness testimony, including by
8
EFTA00031032

=== Page 9 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 9 of 13
allowing witnesses to alter their testimony to conform to other evidence, or influence potential
jurors' perceptions of witness testimony or evidence. Alternatively, as described above, if
evidence of Epstein's suicide is excluded from evidence at trial, pre-trial publication of these
materials would risk exposing potential jurors for or against the defendants in the Noel action on
the basis of material they would otherwise not be shown during trial, which would impair the
government's (and the defendants') ability to seat a fair and impartial jury.
26.
Providing more detailed public descriptions of the withheld documents and how
their release would interfere with the Noel prosecution would itself risk interfering with the Noel
prosecution. For example, public disclosure of more detailed descriptions of the documents
anticipated to be proffered as exhibits at trial, or that bear on other trial exhibits, would disclose
elements of the Government's trial strategy in Noel, including its selection of trial exhibits and
the anticipated content of witness testimony. More detailed public descriptions could also
prematurely disclose how the prosecution team expects the trial to proceed.
Records Withheld Pursuant to Exemption 7(A) on
Account of Likely Interference With Tartaglione
27.
In the course of reviewing the responsive records that BOP has withheld pursuant
to Exemption 7(A), prosecutors in the Criminal Division of the USAO-SDNY determined that
certain of the records refer to or discuss Tartaglione (the "Tartaglione Records"). Upon
determining that some of the records withheld by BOP refer to or discuss Tartaglione, USAO-
SDNY reviewed these records to determine whether their release would interfere with the
pending criminal action against Tartaglione. USAO-SDNY has concluded that release of certain
of the withheld records could reasonably be expected to interfere with the prosecution of
Tartaglione. This constitutes a basis to withhold these records under Exemption 7(A),
independent from the likely interference with the Noel prosecution discussed above.
9
EFTA00031033

=== Page 10 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 10 of 13
28.
The Tartaglione Records fall within several categories of responsive documents
withheld by BOP and include reports and evidence of Epstein's July 23, 2019 apparent suicide
attempt; reports and evidence of Epstein's death on August 10, 2019; email correspondence
between Tartaglione's attorneys and legal counsel at the MCC; and medical and psychological
records of Epstein prepared by BOP. The Tartaglione Records also include emails pertaining to
Epstein's July 23, 2019 apparent suicide attempt, Epstein's mental and physical health, and
Epstein's incarceration prior to his suicide.
29.
The Tartaglione Records fall within the scope of 7(A) because their disclosure
could reasonably be expected to interfere with the prosecution of Tartaglione. The Tartaglione
Records contain, among other things, information about Tartaglione's incarceration, including
the period of time during which Tartaglione was Epstein's cellmate at the MCC, which includes
the date of Epstein's apparent suicide attempt on July 23, 2019. The conditions of Tartaglione's
confinement at the MCC, as well as his interactions with Epstein in July 2019, have been put
directly at issue by Tartaglione's defense counsel, specifically in connection with the potential
penalty phase of the case against Tartaglione. See Letter dated January 13, 2010, Dkt. No. 186,
United States V. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No.
193, United States V. Tartaglione, No. 16 Cr. 832 (KMK). In light of defense counsel's position,
information contained in the Tartaglione Records may be relevant evidence in any possible
penalty phase of the case against Tartaglione, and as a result, premature public disclosure of the
Tartaglione Records could reasonably be expected to influence witness testimony and/or
potential jurors' perceptions of witness testimony or evidence.
30.
Moreover, the nature of the charges against Epstein and the circumstances of his
apparent suicide attempt and death create a risk that premature public disclosure of the
Tartaglione Records could reasonably be expected to impair the government's (and the
10
EFTA00031034

=== Page 11 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 11 of 13
defendants') ability to seat a fair and impartial jury in Tartaglione, particularly for purposes of a
potential penalty-phase hearing required by 18 U.S.C. $ 3593, by influencing potential juror
perceptions of any interactions between Epstein and Tartaglione.
31.
The risks of interference with the Tartaglione proceedings are heightened by the
media coverage of speculation and theories about Epstein's death. As noted previously, many
publicly-discussed theories of Epstein's death are unfounded. The public dissemination of these
theories increases the risk that premature release of the Tartaglione Records could influence
witness testimony or jurors' perceptions, if records are released in part or without full context.
32.
The Tartaglione Records include several categories of records withheld by BOP.
Specifically, the government anticipates that premature disclosure of the reports and evidence of
Epstein's July 23, 2019 apparent suicide attempt; an inmate investigative report prepared prior to
Epstein's death; reports and evidence of Epstein's death on August 10, 2019; email
correspondence between Tartaglione's attorneys and legal counsel at the MCC; the August 8,
2019 review of inmates in the SHU at MCC; and the medical and psychological records of
Epstein prepared by BOP, including documents pertaining to his mental health, could reasonably
be expected to adversely affect the Tartaglione proceedings and influence potential jurors'
perceptions of Tartaglione, thereby impairing the district court's ability to seat a fair and
impartial jury. In addition, emails pertaining to Epstein's July 23, 2019 apparent suicide attempt,
Epstein's mental health, and Epstein's incarceration prior to his suicide, including emails that
involve members of the defense or prosecution teams in Tartaglione, discuss topics and
information that could adversely affect the Tartaglione proceedings and influence potential
juror's perceptions of Tartaglione. These records likewise could reasonably be expected to
impair the district court's ability to seat a fair and impartial jury.
11
EFTA00031035

=== Page 12 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 12 of 13
33.
Providing more detailed public descriptions of the withheld documents and how
their release would affect the Tartaglione prosecution would itself risk interfering with the
Tartaglione prosecution. For example, public disclosure of more detailed descriptions would
potentially implicate and publicize associations, interactions, or perceptions of associations or
interactions between Tartaglione and Epstein, thereby risking influencing potential jurors in
proceedings against Tartaglione, including for any sentencing hearing required by 18 U.S.C.
§ 3593.
Segregability
34.
The records withheld in full under Exemption 7(A) are exempt from disclosure in
their entirety under Exemption 7(A). To the extent the records contain any non-exempt
information, such information is inextricably intertwined with information that could reasonably
be expected to interfere with the Noel and/or Tartaglione prosecutions for the reasons discussed
above. The media coverage of speculation and theories about Epstein's death makes the
segregation of any possibly non-exempt information particularly difficult because providing
information pertaining to Epstein (or Tartaglione and Epstein) without complete context can
reasonably be expected to contribute to the dissemination of speculation and theories about his
death. This, in turn, could reasonably be expected to interfere with the district court's ability to
seat a fair and impartial jury in proceedings against Noel, Thomas, and/or Tartaglione, including
for any sentencing hearing required by 18 U.S.C. $ 3593, for the reasons discussed above.
12
EFTA00031036

=== Page 13 ===
Case 1:20-cv-00833-PAE Document 22 Filed 08/05/20 Page 13 of 13
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this 5 day of August 2020.
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern District of New York
13
EFTA00031037

=== Page 14 ===
Case 1:20-cv-00833-PAE Document 22-1 Filed 08/05/20 Page 1 of 21
Exhibit A
EFTA00031038

=== Page 15 ===
Domumentt212-FilEdled.08d92Pagaged 0021
JUDGE TORRES
UNITED STATES DISTRICT COURT
ORIGINAL
SOUTHERN DISTRICT OF NEW YORK
X
INDICTMENT
UNITED STATES OF AMERICA
:
19 Cr
- V. -
:
19 CRIM 830
TOVA NOEL and
:
MICHAEL THOMAS,
:
Defendants.
X
INTRODUCTION
1.
On or about August 10, 2019, TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under their watch in the MCC's Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area of the SHU. To conceal their failure to perform their
duties, NOEL and THOMAS repeatedly signed false certifications
attesting to having conducted multiple counts of inmates when, in
truth and in fact, they never conducted such counts. As a result
of those false statements, the MCC believed prisoners in the SHU
were being regularly monitored and accounted for when, in fact, as
a result of the defendants' conduct, no correctional officer
conducted any count or round of the SHU from approximately 10:30
EFTA00031039

=== Page 16 ===
p.m. on August 9 until approximately 6:30 a.m. on August 10, at
which time, as alleged herein, NOEL and THOMAS discovered the body
of an MCC inmate, Jeffrey Epstein, who had committed suicide
overnight while unobserved.
RELEVANT INDIVIDUALS AND ENTITIES
2. The MCC is a federal administrative detention
facility located in Manhattan that is run by the Federal Bureau of
Prisons ("BOP"). The MCC is one of several facilities used to
house inmates who have been charged with federal crimes in the
Southern District of New York and are awaiting trial. The MCC
employs correctional officers, whose primary duty is to ensure the
care, custody, and control of the inmate population of the MCC.
3. TOVA NOEL, the defendant, has been employed as a
correctional officer at the MCC since approximately 2016. As of
August 2019, NOEL's primary assignment was the SHU. On August 9,
2019, NOEL worked a regular shift from 4 p.m. to 12 a.m. in the
SHU, and then worked an overtime shift from 12 a.m. to 8 a.m. on
August 10, 2019, also in the SHU. NOEL had also worked a regular
shift in the SHU the day before, August 8, 2019, from 12 p.m. to
8 p.m.
4. MICHAEL THOMAS, the defendant, has been employed as
a correctional officer at the MCC since approximately 2007.
Beginning in approximately 2013, THOMAS was assigned to work as a
2
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=== Page 17 ===
materials handler supervisor, although THOMAS regularly worked
overtime shifts as a correctional officer, including in the SHU.
THOMAS worked an overtime shift in the SHU on August 10, 2019,
from 12 a.m. to 8 a.m. THOMAS did not work his regular shift on
August 8 or August 9, 2019, but did work an overtime shift in the
SHU on August 9, 2019 from 12 a.m. to 8 a.m.
5. As detailed herein, Jeffrey Epstein was
incarcerated at the MCC between his arrest on July 6, 2019, and
his suicide on August 10, 2019. Epstein was detained pending
trial in the Southern District of New York on sex trafficking
charges.
THE MCC AND INSTITUTIONAL COUNTS
6. The MCC, which houses approximately 750 inmates at
any given time, assigns inmates to various housing units within
the MCC. The SHU is a housing unit within the MCC where inmates
are securely separated from the general inmate population to ensure
their own safety as well as the safety of staff and other inmates.
The SHU is located on the ninth floor of the MCC, and access to
that floor is controlled by a locked door that can be opened
remotely only by an officer in the MCC's centralized control center
(the "Control Center"), which is located on the first floor of the
MCC. Access into the SHU is also controlled by a second locked
door to which only correctional officers assigned to the SHU have
3
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=== Page 18 ===
keys while on duty. Within the SHU, inmates are assigned to six
separate tiers, each of which can be accessed only via a single
locked door to which the correctional officers assigned to the SHU
have keys while on duty. Each tier has eight cells, each of which
can house either one or two prisoners, and each individual cell -
which is made of cement and metal - is accessed only through a
single locked door, to which only correctional officers assigned
to the SHU have keys while on duty.
7. The BOP requires correctional officers assigned to
guard inmates at the MCC to conduct institution-wide counts of
inmates at regular, scheduled intervals to ensure that each inmate
is alive and accounted for within the MCC (the "institutional
count"). On weekdays, the MCC conducts five institutional counts
at 4 p.m., 10 p.m., 12 a.m., 3 a.m., and 5 a.m. Performing an
institutional count is one of the most basic and essential aspects
of a correctional officer's job, and the count is one of the most
basic and essential functions of daily operation of the MCC. Two
officers are required to perform the institutional count for each
housing unit, including the SHU, and are further required to
document their performance of the count on an official MCC form
called a count slip. To perform the institutional count in the
SHU, two officers must walk from tier to tier to observe and count
each individual inmate.
4
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=== Page 19 ===
8. On the count slip, both correctional officers are
required to fill in the date and time the count was performed,
write the total number of inmates physically present in the unit
counted, and then sign the count slip. Once the correctional
officers have completed and signed the count slips, the count slips
are then collected and delivered to the Control Center, where
officers within the Control Center are responsible for comparing
the count slips from each housing unit to the institution's inmate
roster to ensure that each inmate is accounted for. Only after
all the count slips are collected from each housing unit, and the
numbers on the slips are matched to the institution's inmate
roster, can the institutional count be deemed "cleared" or
completed. If a housing unit's count slip is incorrect or
incomplete, then the institution cannot "clear" the count.
Instead, the count must be completely redone in that housing unit
via a more-intensive version of the institutional count called a
"bed book count," in which officers must compare every individual
inmate to the institution's inmate roster. Records of each
institutional count, including the count slips, are provided to a
supervising official and retained by the MCC.
9. In addition to the institutional count, the BOP
requires correctional officers assigned to the SHU to walk each of
the tiers of the SHU - which is called a "round" - every thirty
5
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=== Page 20 ===
minutes ("30-minute rounds"). Like the institutional counts,
correctional officers conduct 30-minute rounds to ensure that each
inmate is alive and accounted for within his cell. Correctional
officers working in the SHU are required to complete a form, which
is reviewed and signed by their supervisor, documenting the date
and time of each 30-minute round in each tier of the SHU.
EPSTEIN'S PRIOR APPARENT SUICIDE ATTEMPT
10. On July 6, 2019, inmate Jeffrey Epstein was
arrested and detained at the MCC on sex trafficking charges. On
July 10, 2019, Epstein was assigned to the SHU due to, among other
things, risk factors for suicidality and safety concerns relating
to housing him with the MCC's general population.
11. On July 23, 2019, while Epstein was housed in the
SHU, MCC officers responded to an emergency call, and found Epstein
on the floor of his cell with a strip of bedsheet around his neck.
MICHAEL THOMAS, the defendant, was one of the MCC officers who
responded to the incident. Epstein was subsequently transferred
out of the SHU and was placed on suicide watch. Inmates placed
on suicide watch are housed in a cell on the hospital wing floor
of the MCC, and are watched twenty-four hours a day by a staff
member or a specially trained inmate companion.
12. Epstein remained on suicide watch for approximately
twenty-four hours, and then was transferred to psychological
6
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=== Page 21 ===
observation, until July 30, 2019. Psychological observation is
less restrictive than suicide watch, but inmates are still housed
in the hospital wing of the MCC and watched twenty-four hours a
day.
13. On July 30, 2019, Epstein was transferred back to
the SHU, and, at the direction of the MCC's psychological staff,
was required to have an assigned cellmate. Epstein was also
assigned to the cell closest to the correctional officers' desk in
the common area of the SHU, which was approximately fifteen feet
from the cell. Conducting the required institutional counts and
thirty-minute rounds in the SHU were also part of the MCC's
procedures for ensuring the safety of inmates, including Epstein.
EVENTS OF AUGUST 9-10, 2019
14. On August 9, 2019, Epstein's cellmate was
transferred out of the MCC in a routine, pre-arranged transfer at
approximately 8 a.m. Despite the MCC's psychological staff's
direction that Epstein have a cellmate, no new cellmate was
assigned to Epstein's cell.
15. TOVA NOEL, the defendant, was one of the assigned
officers on duty in the SHU from 4 p.m. on August 9, 2019 to 8
a.m. on August 10. From 4 p.m. to 12 a.m., two other officers
were on duty with NOEL in the SHU: one officer was assigned to
work from 2 p.m. to 10 p.m. ("Officer-1"), and one officer was
7
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=== Page 22 ===
assigned to work from 4 p.m. to 12 a.m. ("Officer-2"). MICHAEL
THOMAS, the defendant, started his shift in the SHU at 12 a.m. on
August 10. From 12 a.m. until 8 a.m. on August 10, NOEL and THOMAS
were the only two officers on duty in the SHU.
16. During the time period from 4 p.m. on August 9 to
8 a.m. on August 10, the officers on duty in the SHU, including
TOVA NOEL and MICHAEL THOMAS, the defendants, were responsible for
conducting five institutional counts: 4 p.m. and 10 p.m. on August
9; and 12 a.m., 3 a.m., and 5 a.m. on August 10. NOEL, THOMAS and
the other officers on duty were also responsible for completing
paperwork attesting to each of those counts. While, as detailed
herein, count slips were completed for each institutional count,
in fact, not a single one of those institutional counts was done.
17. TOVA NOEL, the defendant, and Officer-1 were
responsible for conducting the 4 p.m. institutional count in the
SHU. As video from the MCC's internal video surveillance system
makes clear, NOEL and Officer-1 did not perform the 4 p.m. count.
Nonetheless, NOEL and Officer-1 completed and signed a count slip
that falsely stated that the 4 p.m. institutional count had been
performed. In reliance on that falsified count slip, at
approximately 5:03 p.m., the Control Center cleared the 4 p.m.
count.
8
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=== Page 23 ===
d020 21
18. That evening, Epstein returned to the SHU from his
attorney visit and was escorted into his cell by TOVA NOEL, the
defendant, and another officer at approximately 7:49 p.m. NOEL
and the other officer left the tier in which Epstein was housed
immediately thereafter.
19. By or before 10 p.m., all inmates in the MCC were
locked in their cells for the night. At or around that time, TOVA
NOEL, the defendant, and Officer-2 were responsible for conducting
the 10 p.m. institutional count in the SHU. However, video from
the MCC's internal video surveillance system shows that NOEL and
Officer-2 did not perform the 10 p.m. count. Nonetheless, NOEL
and Officer-2 completed and signed a count slip falsely stating
that the 10 p.m. institutional count had been performed. In
reliance on that falsified count slip, at approximately 10:36 p.m.,
the Control Center cleared the 10 p.m. count.
20. As reflected on video obtained from the MCC's
internal video surveillance system, at approximately 10:30 p.m. on
August 9, 2019 - after TOVA NOEL, the defendant, had signed and
submitted the 10 p.m. count slip and the institutional count had
been completed - NOEL briefly walked up to, and then walked back
from, the door to the tier in which Epstein was housed. As
confirmed by the video obtained from the MCC's internal video
surveillance system, this was the last time anyone, including any
9
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=== Page 24 ===
correctional officer, walked up to, let alone entered, the only
entrance to the tier in which Epstein was housed until
approximately 6:30 a.m. on August 10.
21. Officer-1's shift ended at approximately 10 p.m.,
and at approximately 12 a.m., MICHAEL THOMAS, the defendant,
replaced Officer-2, joining TOVA NOEL, the defendant, as the only
two correctional officers on duty in the SHU. NOEL and THOMAS
were responsible for conducting the 12 a.m. institutional count in
the SHU. As confirmed by video from the MCC's internal video
surveillance system, NOEL and THOMAS did not perform the 12 a.m.
count. Nonetheless, NOEL and THOMAS completed and signed a count
slip for the 12 a.m. count that falsely stated that the
institutional count had been performed. In reliance on that
falsified count slip, at approximately 12:49 a.m., the Control
Center cleared the 12 a.m. count.
22. TOVA NOEL and MICHAEL THOMAS, the defendants, were
additionally responsible for conducting the 3 a.m. and 5 a.m.
institutional counts in the SHU. As confirmed by video from the
MCC's internal video surveillance system, NOEL and THOMAS did not
perform either the 3 a.m. or the 5 a.m. counts. NOEL and THOMAS
nonetheless completed and signed count slips for both counts that
falsely stated that they had performed the 3 a.m. and 5 a.m.
institutional counts. In reliance on those falsified count slips,
10
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=== Page 25 ===
at approximately 3:24 a.m. and 5:30 a.m., the Control Center
cleared the 3 a.m. and 5 a.m. counts, respectively.
23. Moreover, despite the requirement that officers on
duty in the SHU conduct and document regular, 30-minute rounds,
TOVA NOEL and MICHAEL THOMAS, the defendants, did not perform any
of the required 30-minute rounds during their shift between
approximately 12 a.m. and 6:30 a.m. Nonetheless, NOEL completed
and signed more than 75 separate 30-minute round entries falsely
affirming that they had, in fact, conducted such rounds.
24. During the night, instead of completing the
required counts and rounds, TOVA NOEL and MICHAEL THOMAS, the
defendants, were seated at the correctional officers' desk in the
SHU common area (as noted above, approximately 15 feet from
Epstein's cell), used the computers, and moved around the SHU
common area. For a period of approximately two hours, NOEL and
THOMAS sat at their desk without moving, and appeared to have been
asleep. NOEL used the computer periodically throughout the night,
including to search the internet for furniture sales and benefit
websites. THOMAS used the computer briefly around 1 a.m., 4 a.m.,
and 6 a.m. to search for motorcycle sales and sports news.
25. At approximately 4 a.m., the overnight supervisor
briefly visited NOEL and THOMAS in the SHU, and conferred with
NOEL and THOMAS, who were seated at and around the officers' desk,
11
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=== Page 26 ===
before leaving. At approximately 5:30 a.m., another correctional
officer briefly walked through the SHU common area. Aside from
those two officers, as confirmed by video surveillance, no one
else entered the SHU, no one conducted any counts or rounds
throughout the night, and no one entered the tier in which Epstein
was housed.
26. Shortly after 6 a.m. on August 10, 2019, MICHAEL
THOMAS and TOVA NOEL, the defendants, received a delivery of
breakfast carts into the SHU, after which time they were again the
only officers in the SHU. Shortly after 6:30 a.m., NOEL and THOMAS
walked up to and entered the tier in which Epstein was housed to
serve breakfast. At approximately 6:33 a.m., an alarm was
activated in the SHU. Epstein was alone in his cell and not
responsive, with a noose around his neck. A supervisor who had
just started his shift ("Supervisor-1") responded to the alarm
almost immediately thereafter, and as NOEL approached the door to
the SHU to open the door for Supervisor-1, NOEL told Supervisor-1
that "Epstein hung himself." After arriving in the SHU,
Supervisor-1 spoke with THOMAS and NOEL. NOEL told Supervisor-1
"we did not complete the 3 a.m. nor 5 a.m. rounds." THOMAS stated,
"we messed up," and "I messed up, she's not to blame, we didn't do
any rounds."
12
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=== Page 27 ===
27. Epstein was transferred to a local hospital where
he was declared dead shortly thereafter. The Office of the Chief
Medical Examiner of the City of New York conducted an autopsy and
determined that Epstein had committed suicide by hanging himself.
STATUTORY ALLEGATIONS
COUNT ONE
(Conspiracy)
The Grand Jury charges:
28. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
29. In or about August 2019, in the Southern District
of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
knowingly conspired with each other to:
a. Knowingly defraud the United States by
impairing, obstructing, and defeating the lawful functions of a
department or agency of the United States, to wit, the MCC's
function to ensure the care, custody, and control of its inmate
population.
b. Knowingly make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
13
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=== Page 28 ===
department or agency of the United States, in violation of Title
18, United States Code, Section 1001 (a) (3).
30. In furtherance of the conspiracy and to effect the
illegal objects thereof, TOVA NOEL and MICHAEL THOMAS, the
defendants, committed the following overt acts, among others, in
the Southern District of New York:
a. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 12
a.m. institutional count of the SHU, when they had not in fact
done SO.
b. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 3
a.m. institutional count of the SHU, when they had not in fact
done SO.
C. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 5
a.m. institutional count of the SHU at MCC, when they had not in
fact done SO.
d. On August 10, 2019, NOEL falsely certified that
she and THOMAS had performed a series of 30-minute rounds of the
SHU between 12 a.m. and 6:30 a.m., when they had not in fact done
SO.
(Title 18, United States Code, Section 371)
14
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=== Page 29 ===
COUNT TWO
(False Records - 4 p.m. Count)
The Grand Jury further charges:
31. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
32. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use a false writing or document knowing the same to
contain a materially false, fictitious, and fraudulent statement
and entry with the intent to impede, obstruct, or influence the
investigation or proper administration of any matter within the
jurisdiction of any department or agency of the United States, and
did attempt to do the same, to wit, NOEL created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 4 p.m. institutional count of the SHU, when
she had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT THREE
(False Records - 10 p.m. Count)
The Grand Jury further charges:
33. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
15
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=== Page 30 ===
34. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use a false writing or document knowing the same to
contain a materially false, fictitious, and fraudulent statement
and entry with the intent to impede, obstruct, or influence the
investigation or proper administration of any matter within the
jurisdiction of any department or agency of the United States, and
did attempt to do the same, to wit, NOEL created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 10 p.m. institutional count of the SHU, when
she had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT FOUR
(False Records - 12 a.m. Count)
The Grand Jury further charges:
35. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
36. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
16
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=== Page 31 ===
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
performed the 12 a.m. institutional count of the SHU, when they
had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT FIVE
(False Records - 3 a.m. Count)
The Grand Jury further charges:
37. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
38. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
17
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=== Page 32 ===
performed the 3 a.m. institutional count of the SHU, when they had
not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT SIX
(False Records - 5 a.m. Count)
The Grand Jury further charges:
39. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
40. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
18
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=== Page 33 ===
performed the 5 a.m. institutional count of the SHU, when they had
not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
Tracy FOREPERSON
GEOFFREY S BERMAN
Geoffing S. Bermon
United States Attorney
19
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=== Page 34 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- V. -
TOVA NOEL and
MICHAEL THOMAS,
Defendants.
INDICTMENT
19 Cr.
Title 18, United States Code,
Sections 371, 1001 (a) (3), and 2.
GEOFFREY S. BERMAN
United States Attorney
A TRUE BILL
Gay Math Foreperson.
2 ARREST warrants
Indictment Filed
Assigned to Judge TORRES
Hon. Sarah Netburn, USMJ
@
11/19/19
EFTA00031058

=== Page 35 ===
Case 1:20-cv-00833-PAE Document 22-2 Filed 08/05/20 Page 1 of 21
Exhibit B
EFTA00031059

=== Page 36 ===
Case 1:26-cv-00833-RMK Document 220 Filed 04/05/20 twent flud Page 4/16/19 P off 20
Courtflow
3mins
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
SUPERSEDING INDICTMENT
:
- V. -
S4 16 Cr. 832 (KMK)
:
NICHOLAS TARTAGLIONE,
:
Defendant.
:
X
COUNT ONE
The Grand Jury charges:
1.
From at least in or about 2015, up to and
including in or about April 2016, in the Southern District of
New York and elsewhere, NICHOLAS TARTAGLIONE, the defendant, and
others known and unknown, intentionally and knowingly did
combine, conspire, confederate, and agree together and with each
other to violate the narcotics laws of the United States.
2. It was a part and an object of the conspiracy
that NICHOLAS TARTAGLIONE, the defendant, and others known and
unknown, would and did distribute and possess with intent to
distribute a controlled substance, in violation of Title 21,
United States Code, Section 841 (a) (1).
3. The controlled substance that NICHOLAS
TARTAGLIONE, the defendant, conspired to distribute and possess
with intent to distribute was 5 kilograms and more of mixtures
EFTA00031060

=== Page 37 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 2 of 21
and substances containing a detectable amount of cocaine, in
violation of Title 21, United States Code, Section 841 (b) (1) (A).
(Title 21, United States Code, Section 846.)
COUNT TWO
The Grand Jury further charges:
4. In or about April 2016, in the Southern District
of New York, while engaged in an offense punishable under
Section 841 (b) (1) (A) of Title 21, United States Code, to wit, a
conspiracy to distribute, and to possess with the intent to
distribute, 5 kilograms and more of mixtures and substances
containing a detectable amount of cocaine, NICHOLAS TARTAGLIONE,
the defendant, intentionally and knowingly killed, and
counseled, commanded, induced, procured, and caused the
intentional killing of Martin Luna, in and around a bar known as
the Likquid Lounge at 69 Brookside Avenue, Chester, New York
(the "Likquid Lounge"), and did aid and abet the same.
(Title 21, United States Code, Section 848 (e) (1) (A);
Title 18, United States Code, Section 2.)
COUNT THREE
The Grand Jury further charges:
5. In or about April 2016, in the Southern District
of New York, while engaged in an offense punishable under
Section 841 (b) (1) (A) of Title 21, United States Code, to wit, a
conspiracy to distribute, and to possess with the intent to
2
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=== Page 38 ===
Case 1:26-cv-00833-RMK Document 22-2 Filled 04/05/20 Page 31 of 21
distribute, 5 kilograms and more of mixtures and substances
containing a detectable amount of cocaine, NICHOLAS TARTAGLIONE,
the defendant, intentionally and knowingly killed, and
counseled, commanded, induced, procured, and caused the
intentional killing of Urbano Santiago, in and around the
vicinity of 419 Old Mountain Road in Otisville, New York, and
did aid and abet the same.
(Title 21, United States Code, Section 848 (e) (1) (A);
Title 18, United States Code, Section 2.)
COUNT FOUR
The Grand Jury further charges:
6. In or about April 2016, in the Southern District
of New York, while engaged in an offense punishable under
Section 841 (b) (1) (A) of Title 21, United States Code, to wit, a
conspiracy to distribute, and to possess with the intent to
distribute, 5 kilograms and more of mixtures and substances
containing a detectable amount of cocaine, NICHOLAS TARTAGLIONE,
the defendant, intentionally and knowingly killed, and
counseled, commanded, induced, procured, and caused the
intentional killing of Miguel Luna, in and around the vicinity
of 419 Old Mountain Road in Otisville, New York, and did aid and
abet the same.
(Title 21, United States Code, Section 848 (e) (1) (A) ;
Title 18, United States Code, Section 2.)
3
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=== Page 39 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 4 of 21
COUNT FIVE
The Grand Jury further charges:
7.
In. or about April 2016, in the Southern District
of New York, while engaged in an offense punishable under
Section 841 (b) (1) (A) of Title 21, United States Code, to wit, a
conspiracy to distribute, and to possess with the intent to
distribute, 5 kilograms and more of mixtures and substances
containing a detectable amount of cocaine, NICHOLAS TARTAGLIONE,
the defendant, intentionally and knowingly killed, and
counseled, commanded, induced, procured, and caused the
intentional killing of Hector Gutierrez, in and around the
vicinity of 419 Old Mountain Road in Otisville, New York, and
did aid and abet the same.
(Title 21, United States Code, Section 848 (e) (1) (A);
Title 18, United States Code, Section 2.)
COUNT SIX
The Grand Jury further charges:
8. On or about April 11, 2016, in the Southern
District of New York, NICHOLAS TARTAGLIONE, the defendant,
willfully and knowingly, during and in relation to a drug
trafficking crime for which he may be prosecuted in a court of
the United States, namely, the narcotics conspiracy charged in
Count One of this Indictment, did use and carry a firearm, and,
in furtherance of such drug trafficking crime, did possess a
4
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=== Page 40 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 5 of 21
firearm, and in the course of that drug trafficking crime did,
through the use of a firearm, cause the death of Urbano
Santiago, which killing was murder as defined in Title 18,
United States Code, Section 1111(a), and did aid and abet the
same.
(Title 18, United States Code, Sections 924(j) and 2.)
COUNT SEVEN
The Grand Jury further charges:
9. On or about April 11, 2016, in the Southern
District of New York, NICHOLAS TARTAGLIONE, the defendant,
willfully and knowingly, during and in relation to a drug
trafficking crime for which he may be prosecuted in a court of
the United States, namely, the narcotics conspiracy charged in
Count One of this Indictment, did use and carry a firearm, and,
in furtherance of such drug trafficking crime, did possess a
firearm, and in the course of that drug trafficking crime did,
through the use of a firearm, cause the death of Miguel Luna,
which killing was murder as defined in Title 18, United States
Code, Section 1111(a), and did aid and abet the same.
(Title 18, United States Code, Sections 924(j) and 2.)
COUNT EIGHT
The Grand Jury further charges:
10. On or about April 11, 2016, in the Southern
District of New York, NICHOLAS TARTAGLIONE, the defendant,
5
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=== Page 41 ===
Case 1:26-cv-00833-RK Document 220 Filled 04/05/20 Page 6 of 21
willfully and knowingly, during and in relation to a drug
trafficking crime for which he may be prosecuted in a court of
the United States, namely, the narcotics conspiracy charged in
Count One of this Indictment, did use and carry a firearm, and,
in furtherance of such drug trafficking crime, did possess a
firearm, and in the course of that drug trafficking crime did,
through the use of a firearm, cause the death of Hector
Gutierrez, which killing was murder as defined in Title 18,
United States Code, Section 1111 (a), and did aid and abet the
same.
(Title 18, United States Code, Sections 924(j) and 2.)
COUNT NINE
The Grand Jury further charges:
11. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, and others known and unknown, unlawfully and
knowingly did conspire to violate Title 18, United States Code,
Section 1201.
12. It was a part and an object of the conspiracy
that NICHOLAS TARTAGLIONE, the defendant, and others known and
unknown, would and did unlawfully seize, confine, inveigle,
decoy, kidnap, abduct, and carry away and hold for ransom and
reward and otherwise a person, and used a means, facility, and
instrumentality of interstate and foreign commerce in committing
6
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=== Page 42 ===
Case 1:26-cv-00833-RK Document 220 Filled 04/05/20 Page B of 21
and in furtherance of the commission of the offense, to wit,
TARTAGLIONE and others known and unknown agreed to inveigle,
sei,ze, and confine Martin Luna, Urbano Santiago, Miguel Luna,
and Hector Gutierrez in and around the Likquid Lounge.
Overt Act
13. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt act, among
others, was committed in the Southern District of New York and
elsewhere:
a. On or about April 11, 2016, NICHOLAS
TARTAGLIONE and others lured Martin Luna to the Likquid Lounge,
where TARTAGLIONE and others confined Martin Luna, Urbano
Santiago, Miguel Luna, and Hector Gutierrez and would not permit
them to leave the premises.
(Title 18, United States Code, Section 1201 (c) )
COUNT TEN
The Grand Jury further charges:
14. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, and others known and unknown, unlawfully, willfully,
and knowingly did seize, confine, inveigle, decoy, kidnap,
abduct, and carry away and hold for ransom and reward and
otherwise a person, and used a means, facility, and
instrumentality of interstate and foreign commerce in committing
7
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=== Page 43 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 8 of 21
and in furtherance of the commission of the offense, and did aid
and abet the same, to wit, TARTAGLIONE lured Martin Luna to the
Likquid Lounge and confined Martin Luna in and around the
Likquid Lounge, which resulted in the death of Martin Luna.
(Title 18, United States Code, Sections 1201 (a) (1) and 2.)
COUNT ELEVEN
The Grand Jury further charges:
15. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, and others known and unknown, unlawfully, willfully,
and knowingly did seize, confine, inveigle, decoy, kidnap,
abduct, and carry away and hold for ransom and reward and
otherwise a person, and used a means, facility, and
instrumentality of interstate and foreign commerce in committing
and in furtherance of the commission of the offense, and did aid
and abet the same, to wit, TARTAGLIONE and others seized and
confined Urbano Santiago in and around the Likquid Lounge and in
and around the vicinity of 419 Old Mountain Road in Otisville,
New York, which resulted in the death of Urbano Santiago.
(Title 18, United States Code, Sections 1201 (a) (1) and 2.)
COUNT TWELVE
The Grand Jury further charges:
16. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
8
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=== Page 44 ===
11 Filed 08/05/29 Page 9006221
defendant, and others known and unknown, unlawfully, willfully,
and knowingly did seize, confine, inveigle, decoy, kidnap,
abduct, and carry away and hold for ransom and reward and
otherwise a person, and used a means, facility, and
instrumentality of interstate and foreign commerce in committing
and in furtherance of the commission of the offense, and did aid
and abet the same, to wit, TARTAGLIONE and others seized and
confined Miguel Luna in and around the Likquid Lounge and in and
around the vicinity of 419 Old Mountain Road in Otisville, New
York, which resulted in the death of Miguel Luna.
(Title 18, United States Code, Sections 1201 (a) (1) and 2.)
COUNT THIRTEEN
The Grand Jury further charges:
17. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, and others known and unknown, unlawfully, willfully,
and knowingly did seize, confine, inveigle, decoy, kidnap,
abduct, and carry away and hold for ransom and reward and
otherwise a person, and used a means, facility, and
instrumentality of interstate and foreign commerce in committing
and in furtherance of the commission of the offense, and did aid
and abet the same, to wit, TARTAGLIONE and others seized and
confined Hector Gutierrez in and around the Likquid Lounge and
in and around the vicinity of 419 Old Mountain Road in
9
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=== Page 45 ===
Case 1:26-cv-00833-RME Document 220 Filled 04/05/20 Page 110 off 20
Otisville, New York, which resulted in the death of Hector
Gutierrez.
(Title 18, United States Code, Sections 1201 (a) (1) and 2.)
COUNT FOURTEEN
The Grand Jury further charges:
18. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, knowingly traveled in interstate and foreign commerce
and used the mails and any facility in interstate and foreign
commerce with intent to commit a crime of violence, namely,
assault and murder, to further an unlawful activity, namely, a
business enterprise involving a controlled substance, and with
intent to promote, manage, establish, and carry on, and
facilitate the promotion, management, establishment, and
carrying on of the unlawful activity, and thereafter did perform
a crime of violence to further the unlawful activity, and did
aid and abet the same, and death resulted, to wit, TARTAGLIONE
arranged for Martin Luna to be lured to the Likquid Lounge,
where Luna was killed.
(Title 18, United States Code, Sections 1952
and 2.)
COUNT FIFTEEN
The Grand Jury further charges:
19. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
10
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=== Page 46 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 112 off 20
defendant, knowingly traveled in interstate and foreign commerce
and used the mails and any facility in interstate and foreign
commerce with intent to commit a crime of violence, namely,
assault and murder, to further an unlawful activity, namely, a
business enterprise involving a controlled substance, and with
intent to promote, manage, establish, and carry on, and
facilitate the promotion, management, establishment, and
carrying on of the unlawful activity, and thereafter did perform
a crime of violence to further the unlawful activity, and did
aid and abet the same, and death resulted, to wit, after Urbano
Santiago accompanied Martin Luna to the Likquid Lounge, where
Luna had been lured by TARTAGLIONE and others, Urbano Santiago
was held captive, transported to the vicinity of 419 Old
Mountain Road in Otisville, New York, and killed.
(Title 18, United States Code, Sections 1952
and 2.)
COUNT SIXTEEN
The Grand Jury further charges:
20. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, knowingly traveled in interstate and foreign commerce
and used the mails and any facility in interstate and foreign
commerce with intent to commit a crime of violence, namely,
assault and murder, to further an unlawful activity, namely, a
business enterprise involving a controlled substance, and with
11
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=== Page 47 ===
Case 1:26-v-00833-RME Document 220 Filled 04/05/20 Page 13 off 20
intent to promote, manage, establish, and carry on, and
facilitate the promotion, management, establishment, and
carrying on of the unlawful activity, and thereafter did perform
a crime of violence to further the unlawful activity, and did
aid and abet the same, and death resulted, to wit, after Miguel
Luna accompanied Martin Luna to the Likquid Lounge, where Martin
Luna had been lured by TARTAGLIONE and others, Miguel Luna was
held captive, transported to the vicinity of 419 Old Mountain
Road in Otisville, New York, and killed.
(Title 18, United States Code, Sections 1952
and 2.)
COUNT SEVENTEEN
The Grand Jury further charges:
21. On or about April 11, 2016, in the Southern
District of New York and elsewhere, NICHOLAS TARTAGLIONE, the
defendant, knowingly traveled in interstate and foreign commerce
and used the mails and any facility in interstate and foreign
commerce with intent to commit a crime of violence, namely,
assault and murder, to further an unlawful activity, namely, a
business enterprise involving a controlled substance, and with
intent to promote, manage, establish, and carry on, and
facilitate the promotion, management, establishment, and
carrying on of the unlawful activity, and thereafter did perform
a crime of violence to further the unlawful activity, and did
aid and abet the same, and death resulted, to wit, after Hector
12
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=== Page 48 ===
Case 1:26-cv-00833-RME Document 220 Filled 04/05/20 Page 1134 off 20
Gutierrez accompanied Martin Luna to the Likquid Lounge, where
Luna had been lured by TARTAGLIONE and others, Hector Gutierrez
was held captive, transported to the vicinity of 419 Old
Mountain Road in Otisville, New York, and killed.
(Title 18, United States Code, Sections 1952
and 2.)
SPECIAL FINDINGS
22. Counts Two and Ten of this Indictment are
realleged and incorporated by reference as though fully set
forth herein. As to Counts Two and Ten, alleging the
intentional killing of Martin Luna in furtherance of a drug
trafficking crime (Count Two) and the kidnapping resulting in
death of Martin Luna (Count Ten), the defendant NICHOLAS
TARTAGLIONE:
a. was 18 years of age or older at the time of
the offense (Title 18, United States Code, Section 3591 (a) (2) ) ;
b. intentionally killed the victim (Title 18,
United States Code, Section 3591 (a) (2) (A) ) ;
C. intentionally inflicted serious bodily
injury that resulted in the death of the victim (Title 18,
United States Code, Section 3591 (a) (2) (B) ) ;
d.
intentionally participated in an act,
contemplating that the life of a person would be taken and
intending that lethal force would be used in connection with a
13
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=== Page 49 ===
Case 1:26-cv-00833-RME Document 220 Filled 04/05/20 Page 114 off 20
person, other than one of the participants in the offense, and
the victim died as a direct result of the act (Title 18, United
States Code, Section 3591 (a) (2) (C) ) ;
e. intentionally and specifically engaged in an
act of violence, knowing that the act created a grave risk of
death to a person, other than one of the participants in the
offense, such that participation in the act constituted a
reckless disregard for human life and the victim died as a
direct result of the act (Title 18, United States Code, Section
3951 (a) (2) (D) ;
f. caused the death, and injury resulting in
death, of the victim, during the commission of an offense under
Title 18, United States Code, Section 1201 (kidnapping) (Title
18, United States Code, Section 3592 (c) (1) ;
g. committed the offense in an especially
heinous, cruel, and depraved manner in that it involved torture
and serious physical abuse to the victim (Title 18, United
States Code, Section 3592 (c) (6) ;
h. committed the offense after substantial
planning and premeditation to cause the death of a person (Title
18, United States Code, Section 3592 (c) (9) ) ; and
i. intentionally killed and attempted to kill
more than one person in a single criminal episode (Title 18,
United States Code, Section 3592 (c) (16)).
14
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=== Page 50 ===
Case 1:26-cv-00833-RME Document 220 Filled 04/05/20 Page 15 off 20
23. Counts Three, Six, and Eleven of this Indictment
are realleged and incorporated by reference as though fully set
forth herein. As to Counts Three, Six, and Eleven, alleging the
intentional killing of Urbano Santiago in furtherance of a drug
trafficking crime (Count Three), the murder of Urbano Santiago
through the use of a firearm in furtherance of a drug
trafficking crime (Count Six), and the kidnapping resulting in
death of Urbano Santiago (Count Eleven), the defendant NICHOLAS
TARTAGLIONE:
a. was 18 years of age or older at the time of
the offense (Title 18, United States Code, Section 3591 (a) (2) ) ;
b. intentionally participated in an act,
contemplating that the life of a person would be taken and
intending that lethal force would be used in connection with a
person, other than one of the participants in the offense, and
the victim died as a direct result of the act (Title 18, United
States Code, Section 3591 (a) (2) (C) ) ;
C. intentionally and specifically engaged in an
act of violence, knowing that the act created a grave risk of
death to a person, other than one of the participants in the
offense, such that participation in the act constituted a
reckless disregard for human life and the victim died as a
direct result of the act (Title 18, United States Code, Section
3951 (a) (2) (D) ;
15
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=== Page 51 ===
Case 1:26-cr-00832-RK Document 220 Filled 04/05/20 Page 1167 off 20
d.
caused the death, and injury resulting in
death, of the victim, during the commission of an offense under
Title 18, United States Code, Section 1201 (kidnapping) (Title
18, United States Code, Section 3592 (c) (1) ) ;
e. committed the offense after substantial
planning and premeditation to cause the death of a person (Title
18, United States Code, Section 3592 (c) (9) ) ; and
f. intentionally killed more than one person in
a single criminal episode (Title 18, United States Code, Section
3592 (c) (16)
24. Counts Four, Seven, and Twelve of this Indictment
are realleged and incorporated by reference as though fully set
forth herein. As to Four, Seven, and Twelve, alleging the
intentional killing of Miguel Luna in furtherance of a drug
trafficking crime (Count Four), the murder of Miguel Luna
through the use of a firearm in furtherance of a drug
trafficking crime (Count Seven), and the kidnapping resulting in
death of Miguel Luna (Count Eleven), the defendant NICHOLAS
TARTAGLIONE:
a. was 18 years of age or older at the time of
the offense (Title 18, United States Code, Section 3591 (a) (2) ) ;
b. intentionally participated in an act,
contemplating that the life of a person would be taken and
intending that lethal force would be used in connection with a
16
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=== Page 52 ===
Case 1:26-cv-00833-RME Document 220 Filled 04/05/20 Page 18 off 20
person, other than one of the participants in the offense, and
the victim died as a direct result of the act (Title 18, United
States Code, Section 3591 (a) (2) (C) ) ;
C. intentionally and specifically engaged in an
act of violence, knowing that the act created a grave risk of
death to a person, other than one of the participants in the
offense, such that participation in the act constituted a
reckless disregard for human life and the victim died as a
direct result of the act (Title 18, United States Code, Section
3951 (a) (2) (D) ;
d. caused the death, and injury resulting in
death, of the victim, during the commission of an offense under
Title 18, United States Code, Section 1201 (kidnapping) (Title
18, United States Code, Section 3592 (c) (1) ) ;
e.
committed the offense after substantial
planning and premeditation to cause the death of a person (Title
18, United States Code, Section 3592 (c) (9) ) ; and
f. intentionally killed more than one person in
a single criminal episode (Title 18, United States Code, Section
3592 (c) (16) ) .
25. Counts Five, Eight, and Thirteen of this
Indictment are realleged and incorporated by reference as though
fully set forth herein. As to Counts Five, Eight, and Thirteen,
alleging the intentional killing of Hector Gutierrez in
17
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=== Page 53 ===
Case 1:26-cv-00833-RME Document 220 Filed 04/05/20 Page 18 off 20
furtherance of a drug trafficking crime (Count Five), the murder
of Hector Gutierrez through the use of a firearm in furtherance
of a drug trafficking crime (Count Eight), and the kidnapping
resulting in death of Hector Gutierrez (Count Thirteen), the
defendant NICHOLAS TARTAGLIONE:
a. was 18 years of age or older at the time of
the offense (Title 18, United States Code, Section 3591 (a) (2) ) ;
b. intentionally participated in an act,
contemplating that the life of a person would be taken and
intending that lethal force would be used in connection with a
person, other than one of the participants in the offense, and
the victim died as a direct result of the act (Title 18, United
States Code, Section 3591 (a) (2) (C) ;
C. intentionally and specifically engaged in an
act of violence, knowing that the act created a grave risk of
death to a person, other than one of the participants in the
offense, such that participation in the act constituted a
reckless disregard for human life and the victim died as a
direct result of the act (Title 18, United States Code, Section
3951 (a) (2) (D) ;
d. caused the death, and injury resulting in
death, of the victim, during the commission of an offense under
Title 18, United States Code, Section 1201 (kidnapping) (Title
18, United States Code, Section 3592 (c) (1) ) ;
18
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=== Page 54 ===
Case 1:26-cv-00833-RMK Document 220 Filed 08/05/20 Page 20 off 20
e.
committed the offense after substantial
planning and premeditation to cause the death of a person (Title
18, United States Code, Section 3592 (c) (9) ); and
f. intentionally killed more than one person in
a single criminal episode (Title 18, United States Code, Section
3592 (c) (16) )
CRP
GEOFFREY S. S, BERMAN Berman
United States Attorney
19
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=== Page 55 ===
Case 1:26-cv-00833-RMK Document 220 Filled 04/05/20 Page 20 off 20
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- V. -
NICHOLAS TARTAGLIONE,
Defendant.
SUPERSEDING INDICTMENT
S4 16 Cr. 832 (KMK)
(21 U.S.C. $$ 846 and 848 (e) ;
18 U.S.C. §§ 924 (j), 1201 (c),
1201 (a) (1), 1952, and 2.)
od
GEOFFREY S. BERMAN
Foreperson
United States Attorney.
EFTA00031079


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Pending FOIA # 1424728 - JEFFREY EPSTEIN --- UNCLASSIFIED
Date: Fri, 25 Jan 2019 19:35:08 +0000
Attachments: 1424728.pd
Classification: UNCLASSIFIED
TRANSITORY RECORD
Please reply all to below FOIA request. Due 1/31.
Thank you.
From:
Sent: Thursday, January 24, 2019 11:33 AM
To:
Cc:
Subject: Pending FOIA # 1424728 - JEFFREY EPSTEIN UNCLASSIFIED
Classification: UNCLASSIFIED
TRANSITORY RECORD
*Your response to this communication is required within 7 days and is accounted for in the "Percentage of Timely FOIA
Requests" element of your Field Office Health Measure.
Good afternoon,
I am processing a FOIA request and the subject is Jeffrey Epstein.
The requester's name is Bill Stevens. In searching the Bureau's indices, the following file was located and determined
responsive to the subject of this FOIPA request. It is RIDS policy to notify the CDC and Case Agent to ensure all pending
investigations are handled appropriately.
FILE NUMBER (including sub-files): 31E-NY-3027571
Investigator/SA:
RIDS is required to collect and review the potentially responsive information to determine how to properly respond to this
FOIPA request. Below you will find RIDS standard questions for handling pending cases. We request your office address
each question and provide the specific details associated with this pending matter. Your responses to the questions below
will determine the exemptions or whether exclusion is appropriate for this request.
If you have any questions please feel free to contact me at
Thank you for your assistance.
1. What is the current status of the pending investigation (e.g., investigation is ongoing, awaiting U.S. Attorney decision to
prosecute, trial is pending, an appeal from the trial is pending, etc.)?
2. Can we advise the subject/requester that the investigation is pending or would this jeopardize the investigation?
EFTA00030113

=== Page 2 ===
3. If pending, does the investigative file contain any releasable material pertaining specifically to the subject of the request
that will not harm or interfere with this or any other pending investigation?
[Please note releasable material could include, but is not limited to public source material (i.e., newspaper articles, internet
downloads, items in the public domain such as video clips and press releases, court transcripts, criminal affidavits, and other
court filings)].
4. Has the subject of this investigation been interviewed?
Thank you
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED
EFTA00030114


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=== Page 1 ===
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
To:
"
)"
)"
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.
Date: Sun, 09 Aug 2020 22:55:40 +0000
Attachments: letter_to_USA_re_protective_order_(002)_(002)final.pdf
Inline-Images: image001.jpg
Dear Counsel,
Please see attached conferral letter.
Jeff
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing,
distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
attachments without reading or saving it in any manner. Thank you
EFTA00030900


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=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Fri, 09 Apr 2021 02:05:26 +0000
Inline-Images: image001.jpg
Laura,
Below please find responses to the issues you raised:
We are confirmed for the review at the Bronx warehouse on April 12, 2021 from 11am to 4:30pm.
During the April 12th review, your team can see the evidence for yourselves and let me know if you need any of the
items you are not permitted to photograph to be brought to 500 Pearl. Depending on the size of the item(s), we
may need to figure out whether they can be brought later in the week once you have already reviewed several
boxes, which would free up space in the FBI vehicle for the larger items. I'm confident we will be able to reach a
reasonable agreement about those items.
For the bulky photos, you will not be permitted to photograph any that feature nudity. As referenced above, once
your team has seen those photos for yourselves, you can let me know if you will need any to be brought to 500
Pearl.
As I mentioned previously and is indicated in the spreadsheet, we are preparing a letter to defense counsel
explaining why you will not be permitted to review those 16 discs. We expect to send you that letter tomorrow,
after which I will be happy to discuss the matter further.
The blue-ray discs referenced in the spreadsheet are what the FBI burned in order to provide the USAO SDNY with
a copy of electronic data to produce to you in discovery. The discs are not evidence themselves. The data is the
evidence, and it was produced to you already. You are correct, however, that the 4/24/07 file is a data file that was
copied from a VHS tape, which is currently located in the FBI's ELSUR office in Florida. We have asked that the
original tape be shipped to New York, and it should arrive on Tuesday, April 13th. We will make it available for you
to review once we have received it. We also plan to produce the digital file of that same recording to you as part of
our productions of non-testifying witness statements.
The shredded paper is currently being analyzed by the FBI lab. We have asked the case agent to inquire with the
lab regarding its anticipated timeline for analysis and will let you know when we expect it will be possible to have
the shredded paper returned to New York for you to review. It will not, however, be available next week.
The "Missing from Assigned Box" items are items 1B130 and 1B110. Those items were migrated within the FBI
evidence system from the Florida case to the New York case and incorporated into New York evidence item
numbers 1B127, 1B128, & 1B137. So these items will be available for your review under those New York evidence
numbers.
Best,
EFTA00031332

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <lmenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 4:23 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
EFTA00031333

=== Page 3 ===
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
EFTA00031334

=== Page 4 ===
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00031335

=== Page 5 ===
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
EFTA00031336

=== Page 6 ===
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com
Sent: Friday, April 2, 2021 5:36 PM
To:
is
is
(USANYS)
EFTA00031337

=== Page 7 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00031338

=== Page 8 ===
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
EFTA00031339

=== Page 9 ===
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
EFTA00031340

=== Page 10 ===
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
EFTA00031341

=== Page 11 ===
From:
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
EFTA00031342

=== Page 12 ===
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
-
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
EFTA00031343

=== Page 13 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
EFTA00031344

=== Page 14 ===
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043, but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
is
EFTA00031345

=== Page 15 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
EFTA00031346

=== Page 16 ===
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031347

=== Page 17 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00031348


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c3: VOL00008
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=== Page 1 ===
FOR OFFICIAL USE ONLY
INFORMATION PROVIDED BY CBPAS
DATE:
Friday, August 30, 2019
TIME:
0730 hrs
LOCATION:
1601 - CBP CES, Supervisor's office, North Charleston, SC
PURPOSE: Informational.
CBPAS
(Badge # CAS03223 / HashID # CZACMME) stepped into
Superviso
office to provide information that likely is viewed negatively as an
employee of CBP. CBPAS
informed Supervisor
that a lady, female
acquaintance, he had recently dated has informed him she has filed two (2) complaints to law
enforcement against him.
ISSUE 1: Complaint filed to U.S. Department of Justice
Mr.
provided the following information:
The female acquaintance of Mr.
has informed the Federal Department of Justice, that
Mr.
is a known associate of Jeffery Epstein, had ongoing friendship with Mr. Epstein,
and that while working for CBP Pre-Clearance in Saint Thomas for over 7 years, and assisted
Mr. Epstein for conducting human trafficking of underage females.
asked Mr.
how is it possible the female acquaintance would know anything
about his associations or relationships while working in Saint Thomas,
stated.
"Everyone knew I was friends with Jeffery Epstein."
further informed
"I
have been to his house, been on his boat, and flew in helicopter for whale watching."
Hearing this information, Supervisor
recalls previous international travel history
that has taken Mr.
locations for personal rendezvous excursions.
ISSUE 2: Complaint filed to local Charleston County Sheriff Department
Mr.
provided the following information:
The female acquaintance, simultaneously has informed Mr.
that she has lodged a
complaint against Mr.
,
accusing him of predatory behavior, targeting widows, and
vulnerable persons.
Hearing this information, Supervisor
recalls previous statements Mr.
has made, surrounding his previous rent landlord when first arriving to work with CBP
Charleston; the landlord, an older female, with whom he ended up going to court, for
complaint against him for monetary exchange for services around the home (simple home
repairs, to lower costs of rent).
FOR OFFICIAL USE ONLY
EFTA00031495

=== Page 2 ===
FOR OFFICIAL USE ONLY
INFORMATIONAL HIGHLIGHTS:
When
walked into Supervisor
office today, he respectfully requested to
speak in confidence, closed the door, and appeared to be concerned, worried, and a bit
shaken, about federal investigators looking into his past.
opened up the conversation by stating that the person making the complaint is the
same acquaintance that attempted "suicide" on a previous occasion, which
was
informed about, last year when
requested a time off of work to visit the person in
the hospital.
informed
to keep CBP Supervisor
informed of contact made
with outside investigators, because this interaction merits transparency for all future periodic
re-investigations - anytime our actions result in interaction with law enforcement.
reminded
to be careful with all of his relationships, and that having
relationships with unstable, and unethical, people, can be a serious detriment, cause unknown
consequences, and that our choices we make in our personal lives can reflect negatively.
PROGRAM/SUBJECT MATTER BACKGROUND:
Two to three bullets that summarize key historical information on the subject. This can
include, but is not limited to: Previous decisions, negotiations, external stakeholder
interests, legislation, ongoing legal proceedings, etc.
SUMMARY: CBPAS
Charleston S.C., provided information connecting
him to a convicted child molester while working for CBP; with accusations potentially ensnaring
CBP's reputation as an agency, into the mix of a well known criminal, specifically the following:
While at the pre-clearance port of Saint Thomas, USVI (beginning in 2008), Mr.
pal'd around with Mr. Epstein, clearing his aircraft; and spending personal
time with the convict after befriending him, entering into that friendship through carrying
out CBP official duty.
Mr.
has had rocky relationships with previous single female as a landlord,
upon arriving to work for CBP in Charleston, SC (transferring from Saint Thomas,
USVI).
Landlord and Mr.
went to court of monetary instruments
A separate female acquaintance attempted suicide, who is now informing
she
has filed two (2) separate complaints with law enforcement, surrounding history of
behavior. (2 complaints listed above).
Prepared by: SCBPAS
(office)
(mobile)
FOR OFFICIAL USE ONLY
EFTA00031496


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=== Page 1 ===
From:
To:
Subject: SecureMail Message Notice
Date: Fri, 12 Jul 2019 03:33:53 +0000
read this message "RE: Epstein" at 2019-07-12 03:33:53 UTC.
EFTA00030278


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=== Page 1 ===
From:
"
)"
To:
)"
,
)"
Subject: Call w/
lawyers
Date: Fri, 19 Jul 2019 21:28:07 +0000
Importance: Normal
Attachments: unnamed
EFTA00030619


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Florida document release
Date: Thu, 30 Jan 2020 22:10:38 +0000
I'm sure you saw this as well from google alerts, but wanted to flag because this may cause issues:
https://www.sun-sentinel.com/news/crime/fl-ne-jefrey-epstein-documents-online-20200130-
otmyje2wujatphbiafop4pom7e-story.html
http://sa15.org/stateattorney/NewsRoom/indexPR.htm
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
EFTA00029800


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
,
(USANYS)"
Subject: RE: plaintiff counsel request for documents, Epstein case
Date: Mon, 30 Dec 2019 20:48:39 +0000
Following up on our brief discussion of this issue earlier this month, I wanted to see if you had any additional thoughts on
how to handle requests from counsel for plaintiffs who are suing Epstein and his estate who ask us for information or
materials in connection with our investigation - I think you had said we should instruct them to submit Touhy Requests,
and that you would designate a Civil Division person to whom we could have them direct those requests. If that's right,
could you please let us know who that person will be? So far we've just gotten the request from one plaintiff's counsel,
Robbie Kaplan at Kaplan Hecker, and her request is very narrow but we want to set up the system in a way that will work if
we get additional and/or more expansive requests going forward. And we would like to let her know how she should
proceed relatively soon because that case has a status conference on January 10 and I think they'd like to make the
request before then.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00031088


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Letter due tomorrow
Date: Sun, 09 May 2021 16:59:28 +0000
Attachments: 2021-5-10_Govt_Letter_re_Proposed_Trial_Date_v1.docx.
Hope everyone is having a nice weekend. Attached is a draft letter, please feel free to edit freely. I tried to capture
defense counsel's position in this letter, but again, please edit if you think I have missed anything.
asked to see this
later tonight or tomorrow morning so would appreciate any edits by tonight if possible (I'll be in NJ for Mother's Day so
won't be able to turn to it until this evening). Thoughts on responding to
latest email? Should we just say that the
November 29 trial start date would permit the entire team to do the trial?
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:
EFTA00031677


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=== Page 1 ===
From:
Subject: Travel Authorization 11063042 has received final approval
Date: Wed, 19 Feb 2020 19:12:35 +0000
Importance: Normal
Dear
Travel authorization 11063042 has received final approval.
Trip ID: 11063042
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13403 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0006
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00030790


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c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Cc:
(USANYS)"
(USANYS)"
)"
,
(USANYS)"
Subject: Re: 050D-NY-3027571_0000239.pdf
Date: Wed, 11 Nov 2020 21:53:51 +0000
Thanks, we are familiar with this.
On Nov 11, 2020, at 4:47 PM,
)
wrote:
Hi all,
In reviewing FBI reports from the Epstein tip line,
came across the attached report. We wanted to share this
with you in connection with the MCC guards case.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
<050D-NY-3027571_0000239.pdf>
EFTA00029989


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c0:
=== Page 1 ===
Event: Gov't reply to Epstein bail motion due
Start Date: 2019-07-12 21:00:00 +0000
End Date: 2019-07-12 21:30:00 +0000
Organizer:
)
Location: Berman
Class: X-PERSONAL
Date Created: 2019-07-08 20:50:55 +0000
Date Modified: 2019-07-08 20:50:55 +0000
Priority: 5
DTSTAMP: 2019-07-08 20:42:04 +0000
Attendee:
.V.
Alarm: Display the following message 15m before start
I
Reminder
EFTA00030824


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c0:
=== Page 1 ===
From:
To:
Subject: RE: Proffer
Date: Fri, 13 Aug 2021 14:28:23 +0000
Attachments: 2019.08.11_Attorney_Proffer_from_Maurice_Secarz_
).docx
Inline-Images: image001.jpg; image002.jpg
Here you go.
From:
Sent: Friday, August 13, 2021 10:00 AM
To:
Subject: Proffer
Good Morning
Do you have the notes or 302 from the
Attorney Proffer regarding the Epstein August 9th call from the
SHU? Thank you.
Special Agent
U.S. Department of Justice Office of the Inspector General New York Field Office
US
SPECIAL
AGENT
EFTA00030456


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=== Page 1 ===
London
Thurber
Preliminary Title Report
EFFECTIVE
CLIENT REF:
USMS-D54-00000307
06/14/2019 8:00 AM
DATE:
L&T REF:
USMS-D54-00000307
SEARCH DATE:
07/19/2019
PROPERTY ADDRESS:
9 East 71st Street, New York NY 10021
1. Title to Fee Simple estate or interest in the Land described or referred to in this Report is at
the effective date hereof vested in:
Record Owner(s):
Maple, Inc., a U.S. Virginia Islands Corporation
Instrument type:
Deed
Grantor:
Nine East 71st Street Corporation, a New York Corporation
Date:
12/23/2011
Rec. date:
01/10/2012
Rec. Vol.:
2012000008342
Consideration:
$10.00
All as recorded in the public records of New York County, New York
2. The Land referred to in this Report is described as follows:
See attached "Exhibit A"
EFTA00031560

=== Page 2 ===
London
Thurber
Title Report
SCHEDULE B - PART I
REQUIREMENTS
Client File No.: USMS-D54-00000307
The following are the requirements to be complied with; otherwise, they will appear as
exceptions in the final policy to be issued:
1. Pay the agreed amounts for the interest in the land and/or the mortgage to be insured.
2. Pay us the premiums, fees and charges for the policy.
3. Pay all taxes and/or assessments, levied and assessed against the land, which are due and
payable.
4. You must tell us in writing the name of anyone not referred to in this Report who will get an
interest in the land or who will make a loan on the land. We may then make additional
requirements or exceptions.
5. In the Loan Policy to be issued, the company will insure against defects in the title which are
filed for record during the period of time between the effective date of this Report and the
date of filing for record of the documents creating the estate or interest being insured, except
for matters of which the insured has any knowledge. Any provisions in this Report which are
in conflict herewith are hereby deemed deleted.
6. Documents, satisfactory to us, creating the interest in the land and/or the mortgage to be
insured, must be signed, delivered and recorded:
7. Receipt of survey satisfying the Minimum Standard Detail Requirements of the American
Land Title Association dated within 90 days of closing.
8. Owner's Affidavit in a form acceptable to Company
9. Mortgages: None reported
10. Judgments/Liens: None reported
11. Such other matters set forth in Exhibit "B" attached hereto.
EFTA00031561

=== Page 3 ===
London
Thurber
Title Report
SCHEDULE B - PART II
EXCEPTIONS
Client File No.: USMS-D54-00000307
The policy or policies to be issued will contain exceptions to the following unless the same are
disposed of to the satisfaction of the Company:
1. Defects, liens, encumbrances, adverse claims or other matters, if any, created, first appearing
in the public records or attaching subsequent to the effective date hereof but prior to the date
the proposed Insured acquires for value of record the estate or interest or mortgage thereon
covered by this Report.
2. Rights or claims of parties in possession not shown by public records, including, but not
limited to, the rights of tenants in possession, if any, and all parties claiming by, through or
under said tenants.
3. Easements of claims of easements not shown by the public records.
4. Encroachments, overlaps, shortage in area, boundary line disputes or other matters which
would be disclosed by an accurate survey or inspection of the Land.
5. Taxes or special assessments which are not shown as existing liens by the public records.
6. Any bills, fees, charges or taxes for water, sewer, sanitation or other public services.
7. Any lien or right to a lien, for services, labor, or material heretofore or hereafter furnished,
imposed by law and not shown by the public records.
8. No insurance is afforded as to the exact amount of acreage as contained in the captioned
property as described herein.
9. Service Members Civil Relief Act.
10. Any association assessments (special and general) recreational lease payments dues or other
fees, if any.
11. Taxes and special assessments for the year 2019 and all subsequent years, as well as the lien
for any additional taxes for prior years due to reassessments or rebilling.
12. Rights of spouses or parties arising under laws regarding marital homestead, tenancy by the
entireties or marital interests in the subject property.
13. Rights of redemption held by any party with regards to any judicial, quasi-judicial or non-
judicial sale.
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London
Thurber
Title Report
14. The following additional matters stated or referenced in the following items found of record
with regards to the Land: See Exhibit "B"
DISCLAIMER: This title report is prepared based on information furnished to our office by an
independent third-party title examiner. This Report does not contain or constitute a legal opinion
regarding the status of the title to the subject real property. If you require a legal opinion of title
or an attorney title opinion, please let us know and we will obtain a legal opinion or attorney title
opinion from an attorney licensed to practice law in the state in which the property is located.
EFTA00031563

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London
Thurber
Title Report
Exhibit A
Legal Description:
ALL that certain plot, place or parcel of land, with the buildings and improvements thereon
erected, situate, lying and being in the Borough of Manhattan, City, County and State of New
York, bounded and described as follows:
BEGINNING at a point on the northerly side of 71st Street distant 225 feet easterly from the
corner formed by the intersection of the easterly side of 5th Avenue with the northerly side of
71st Street; running
thence Easterly along the northerly side of 71st Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the center line of the block
between 71st and 72nd Streets;
thence Westerly along the said center line and parallel with 71st Street 50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the northerly side of 71st
Street at the point or place of beginning.
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London
Thurber
Title Report
Exhibit "B"
Additional Liens & Encumbrances
1. Satisfaction of Mortgage recorded on 09/28/1988 in Book 1471 at Page 1309.
2. Notice of Designation recorded on 07/02/1982 in Book 629 at Page 739.
EFTA00031565


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
)"
Subject: RE: Questions re Maxwell
Date: Mon, 23 Nov 2020 15:50:24 +0000
Attachments: 2020-11-23_GM_letter_update_re_MDC_conditions_v2.docx
Good morning,
Attached is the final version of the letter to Judge Nathan
This is
the final version that we plan to file. Please let me know ASAP if anything in this letter is inaccurate.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
(USANYS)
Sent: Sunday, November 22, 2020 6:34 PM
To:
Cc:
(USANYS)
is
Subject: RE: Questions re Maxwell
Attached please find a draft update letter to Judge Nathan. Please let me know by the end of the day tomorrow (11/23) if
anything in this letter is inaccurate
Also, if you could please get me responses to the two questions in my below email tomorrow, I'd be very grateful.
Happy to have a call if that would be useful.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
EFTA00030487

=== Page 2 ===
New York, NY 10007
From:
Sent: Friday, November 20, 2020 2:34 PM
To: Nicole McFarland
>; Sophia Papapetru
Cc:
(USANYS)
i
Subject: Questions re Maxwell
Hi
I just got a call from
and we discussed a number of issues regarding Maxwell. The two issues I wanted to follow up
with you about are below:
Maxwell is reporting that a staff member named
or
was part of the group that included a
COVID positive individual but
is still working at the MDC. Would you please check on that for
me?
Maxwell reported that a staff member entered her cell while she was inside it and took photographs of her cell
today. Anything you can share with me about the purpose of that?
More generally
indicated that she believes Maxwell's mental health is deteriorating significantly because of the
constant surveillance she is experiencing. She reports being awoken in the night by a light shining into her eyes multiple
times a night, being searched more frequently than other inmates, and having a camera constantly pointed at her in a way
that other inmates do not experience. Our office of course defers to BOP on decisions regarding what is necessary for
safety and security, but I wanted to pass along the concern.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030488


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=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
)
Six binders with various CDs
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
30 days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
Judge's signature
City and state:
New York, NY
Hon. James L. Cott, United States Magistrate Judge
Printed name and title
EFTA00030741

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AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00030742

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Attachment A
I. Items Subject to Search and Seizure
The Subject Items are particularly described as follows¹:
a.
Two blue binders with CDs, which were seized by Special Agent
from a blue suitcase on or about July 11, 2019 ("Subject Item-1").
b.
Three blue binders with various CDs and one clear binder with a green spine
with various CDs, all four of which were seized by Special Agent
from a black
suitcase on or about July 11, 2019 ("Subject Item-2").
II. Review of ESI on the Subject Items
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Items for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
1.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
2.
Any photographs of victims or potential victims of the Subject Offenses;
3.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
4.
Records, data, or other items that evidence ownership, control, or use of, or access
to the Subject Items, including, but not limited to access history data, historical location data,
configuration files, saved usernames and passwords, user profiles, e-mail contacts, and
photographs;
5.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. $ 2256(8).
1 To the extent that the Subject Items contain any removable storage media, including CDs, the
description of each such item encompasses those other media.
2017.08.02
EFTA00030743

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In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
"scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation; and
reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section II
of this Attachment. However, law enforcement personnel are authorized to conduct a complete
review of all the ESI from seized devices or storage media if necessary to evaluate its contents and
to locate all data responsive to the warrant.
2
2017.08.02
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=== Page 1 ===
From:
To:
Subject: MCC
Date: Tue, 19 Nov 2019 12:55:13 +0000
https://www.wfsb.com/eye-opener-american-professor-freed-impeachment-inquiry-witness-epstein-
th/video 82438e1a-8038-521e-9682-59cc49d78a95.html
This was on my CBS CT affiliate at 5:45 as I walked out the door. Third item in very short report.
EFTA00031101


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=== Page 1 ===
July 12, 2021
prep
AUSAs
&
SA
Det.
Showed
video from October 20, 2005 PBPD SW of JE PB residence
believes she sees either herself or
in the video around 9 min and 50
sec in
vaguely remembers being inside the house and photographing scene
recalls an open computer tower inside the house
reviewed PBPD property receipts from search
Markings at bottom from November 2005 indicate
pulled certain items of
evidence for Det.
Several of those items were returned back to houseman
reviewed photographs from scene and of evidence on brown paper
confirmed consistent with her practice to put evidence seized from a search on
brown paper, with scales, and with evidence numbers to photograph them
recognizes her handwriting on the post-it notes with item numbers in the
photographs of evidence items on brown paper
shown message pads
recognizes her handwriting on the post-its with item numbers, which are the
same post-its in the photos of the evidence items on brown paper
confirmed the message pads look like the ones in the photographs from the
search, but she cannot be more specific in identifying them because she never
looked inside the message pads
recollection is that
bagged all the evidence, and
supervised the
evidence team
EFTA00029872


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=== Page 1 ===
From:
)"
To: "Miller, Michael"
Cc:
)"
)"
"Weingarten, Reid"
>, "Lucas, Morgan"
Subject: RE: United States of America V. Epstein U.S. - 2nd Circuit Docket No. 19-2221
Date: Tue, 20 Aug 2019 17:59:33 +0000
Attachments: Signed_Stipulation_to_Withdraw_Appeal.pdf
Mike,
Received, and signed and attached. Please let me know if any issues.
thanks,
From: Miller, Michael
>
Sent: Tuesday, August 20, 2019 10:57
To:
Cc:
>;
is
;
Weingarten, Reid
>; Lucas, Morgan <
Subject: United States of America V. Epstein U.S. - 2nd Circuit Docket No. 19-2221
If you can sign and return the attached stipulation to withdraw appeal we will file this when we get it back from
you.
Many thanks.
Mike
Michael C. Miller
Partner
fax
Steptoe
Steptoe & Johnson LLP
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message.
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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: Judge Nathan Order re Maxwell
Date: Thu, 29 Apr 2021 15:18:45 +0000
Attachments: 2021.04.29_AJN_Order_re_MDC.pdf
Hi all,
Attached please find an order that Judge Nathan just issued on the docket in Maxwell's case, which directs the MDC to
take certain steps by April 30, 2021.
As always, we are happy to have a call to discuss if that would be useful.
Best,
Assistant United States Attorney
Southern District of New York
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From:
)"
To:
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Date: Tue, 19 Nov 2019 23:55:44 +0000
Attachments: FOLIODETE_20191115122139.pdf
Embedded: RE_travel_invoices_comp_time_(California_trip_Nov_13-15).msg
Sorry but I don't believe this voucher is accurate, similar to the prior one. First, it appears to allocate one night of the
hotel to the travel card, which is incorrect-the entirety of the hotel was paid on my personal card (please see attached
email and I'm again sending the hotel invoice). Additionally, it doesn't appear to include the hotel tax of $ 70.12, which I
also paid on my personal credit card.
Please let me know when it's corrected and l'll review again. Thanks.
From:
Sent: Tuesday. November 19. 2019 18:46
To:
Subject: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Dear
Final voucher 10810414(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810414
Voucher ID: 1
Voucher type: Final
Traveler name
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1517.64
Estimated trip cost: 1583.95
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
EFTA00030424

=== Page 2 ===
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00030425


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
)"
Subject: Epstein SW database
Date: Mon, 25 Jan 2021 16:03:32 +0000
Hi
,
Hope you're doing well. Could you please help us create some review batches for this database? In particular, if
you could please create batches of all materials designated responsive in the search warrant database that hit on
the following terms, that would be very helpful:
-gmax
-gmax1
If the batches could be approximately 500 documents each, that would be great. Thanks!
Sent from my iPhone
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Following up Witness PA
Date: Tue, 30 Jun 2020 18:40:48 +0000
Inline-Images: image001.png; image002.png; image003.png; image004.png
I think we have to stick with the treaty language. As to whatever we file in the USVI, I'd have to see what it is to
opine on whether it is directly related to a US criminal matter. As you note, the answer may be no.
From:
(USANYS)
Sent: Monday, June 29, 2020 1:20 PM
To:
(USANYS)
Subject: RE: Following up Witness PA
On the subject never ends, the State Department would like us to modify our proposed confidentiality language as
follows:
- Absent a court order directing otherwise, U.S. authorities will not use or disclose the
content of the witness's statements in an interview with U.S. authorities in any matter
other than a U.S. criminal investigation or proceeding, and any non-criminal judicial
or administrative proceeding directly related to a U.S. criminal investigation or
proceeding, pursuant to Article 7 of the Treaty.
Do you have thoughts on whether that would be broad enough to include any potential civil action we might pursue in
connection with the Epstein estate in USVI? Not sure we would ever plan to do so, but was trying to preserve the option.
That said, if this is the language of the treaty, not sure how hard we can push back.
From:
(USANYS)
Sent: Friday, June 26, 2020 3:27 PM
To:
(USANYS)
Subject: RE: Following up Witness PA
I think that's OK. Note that Touhy is not entirely discretionary-it applies after a subpoena issues, and our denial
can be reviewed in court. But we can easily insist on a court order. At the beginning of the 302 (and any notes)
the following should be stated:
Note that for purposes of any FOIA request, subpoena/Touhy request, Privacy Act routine use
disclosure, or any other disclosure this document is subject restrictions on disclosure pursuant to
the MLAT pursuant to which the interview took place. Absent a court order directing otherwise,
the SDNY or FBI will not use or disclose the content of the witness's statements in an interview
with law enforcement in any matter other than a criminal investigation, prosecution, or related
civil action or asset forfeiture action initiated by the United States government.
The FBI should really understand that any leak of any of this would be pretty terrible.
From:
(USANYS)
Sent: Friday, June 26, 2020 2:58 PM
To:
USANYS)
Subject: FW: Following up Witness PA
EFTA00031512

=== Page 2 ===
See below for the language of the treaty. In light of that,
has signed off on the following language, but let
me know if you have any concerns:
- Absent a court order directing otherwise, the SDNY or FBI will not use or disclose the
content of the witness's statements in an interview with law enforcement in any
matter other than a criminal investigation, prosecution, or related civil action or asset
forfeiture action initiated by the United States government.
From:
(CRM)
Sent: Friday, June 26, 2020 8:11 AM
To:
(USANYS)
>;
Cc
Subject: RE: Following up Witness PA
The UK could impose conditions on any evidence provided under the MLA treaty. Once the evidence
is provided they typically send a letter to us saying that the evidence is to be used only for the
purposes specified in the MLA request. Our MLA requests track the language of the Treaty, which
gives us use in criminal cases and related forfeiture and administrative actions. It doesn't deal with
FOIA or Touhy. (Since Touhy is discretionary, I assume we would just reject any requests for agent
testimony on this topic.)
Here is the link to the treaty on OIA's intranet page:
http://crmln05.crm.doj.gov:7778/pls/portal/docs/PAGE/OIA/TAB_TREATY_LIBRARY/MLAT/DATA/USEU.MLA.UK.PDIF
Here are the relevant sections:
1bis. Mutual legal assistance shall also be afforded to a national administrative
authority, investigating conduct with a view to a criminal prosecution of the conduct, or
referral of the conduct to criminal investigation or prosecution authorities, pursuant to
its specific administrative or regulatory authority to undertake such investigation.
Mutual legal assistance may also be afforded to other administrative authorities under
such circumstances Assistance shall not be available for matters in which the
administrative authority anticipates that no prosecution or referral, as applicable, will
take place. Requests for assistance under this paragraph shall be transmitted between
the Central Authorities designated pursuant to Article 2 of this Treaty, or between such
other authorities as may be agreed by the Central Authorities
ARTICLE 7
Confidentiality and Limitations on Use
1. The Requested Party shall, upon request, keep confidential any information
which might indicate that a request has been made or responded to. If the request cannot
be executed without breaching confidentiality, the Requested Party shall so inform the
Requesting Party, which shall then determine the extent to which it wishes the request
to be executed
2. The Requesting Party may use any evidence or information obtained from the
Requested Party:
(a) for the purpose of its criminal investigations and proceedings;
(b) for preventing an immediate and serious threat to its public security;
EFTA00031513

=== Page 3 ===
(c) in its non-criminal judicial of administrative proceedings directly related to
investigations or proceedings:
(i)
set forth in subparagraph (a); or
(ii)
for which mutual legal assistance was rendered under Article 1 (1 bis) of
this Treaty:
(d) for any other purpose, if the evidence or information has been made public
within the framework of proceedings for which they were transmitted, or in any of the
situations described in subparagraphs (a), (b) and (c); and
(e) for any other purpose, only with the prior consent of the Requested Party.
3. (a) This Article shall not prejudice the ability of the Requested Party in
accordance with this Treaty to impose additional conditions in a particular case where
the particular request for assistance could not be complied with in the absence of such
conditions Where additional conditions have been imposed in accordance with this
subparagraph, the Requested Party may require the Requesting Party to give
information on the use made of the evidence or information
(b) Generic restrictions with respect to the legal standards of the Requesting
Party for processing personal data may not be imposed by the Requested Party as a
condition under subparagraph (a) to providing evidence or information
4. Where, following disclosure to the Requesting Party, the Requested Party
becomes aware of circumstances that may cause it to seek an additional condition in a
particular case, the Requested Party may consult with the Requesting Party to determine
the extent to which the evidence or information can be protected.
ARTICLE 15
Return of Documents and Articles
The Central Authority of the Requesting Party shall return any documents or
articles furnished to it in the execution of a request under this Treaty as soon as is
practicable unless the Central Authority of the Requested Party waives the return of the
documents or articles.
From:
(USANYS)
Sent: Thursday, June 25, 2020 11:48 PM
To:
Cc:
(CRM)
Subject: Re: Following up
Thanks,
And I'm sorry, my email was not clear
do you have a copy of the actual treaty? Curious as to
whether the treaty itself contemplates limitations on use of information.
Sent from my iPhone
On Jun 25, 2020, at 6:45 PM,
wrote:
The MLAT is attached for reference, thanks.
From:
(USANYS)
Sent: Thursday, June 25, 2020 6:28 PM
To: McNeil, John (CRM)
is
Cc: Chadwick, Amanda J (London)
ChadwickAJ@state.gov
Subject: RE: Following up
Thanks, John. I appreciate the concern and am open to working to address it, to the extent possible. We, of course,
would never simply turn this material over to a civil litigant, as you suggest. The problem is, irrespective of our intent,
this is not Rule 6 material (unless, of course, he testifies before a grand jury), and we are trying to be mindful of not
simply our criminal case, but obligations we may have under other aspects of U.S. law, FOIA and/or Touhy, spring to
mind, for example. Again, we never voluntarily turn this stuff over, and we frequently oppose FOIA requests and the like
to the extent we can under the law. But particularly given the history and concern, we don't want to make promises we
may not be able to keep.
Do you by any chance have handy a copy of the MLAT itself (if not, certainly happy to locate myself, just figured you
might have it already). I'd like to see what, if anything, the treaty says about this subject.
EFTA00031514

=== Page 4 ===
From:
CRM)
Sent: Thursday, June 25, 2020 2:47 PM
To:
Cc:
Subject: RE: Following up
Thanks. This is helpful. One clarification which they will seek - because it seems to loom
large in their suspicions - is whether his statement will be provided to victims for purposes
of civil litigation. I know this is not something that ordinarily happens (I don't think I have
ever done this) - but I think we need to say something about that to move this forward.
Maybe something like, "Absent a court order directing otherwise, the SDNY will not use or
disclose the statement in any matter other than a criminal investigation, prosecution, or
related asset forfeiture action initiated by the United States government."
What do you think?
From:
(USANYS)
Sent: Thursday, June 25, 2020 7:36 PM
To:
(CRM)
>;
Cc:
Subject: RE: Following up
- Thanks for your patience. I've now had a chance to raise your suggestion on our end, and we are amenable to
discussing a confidentiality agreement along the lines you propose, with some revisions. Below is our proposed
language which we would be comfortable with. Happy to discuss our position further at your convenience. Thanks
Prior to the in-person interview:
- From now until August 14, 2020, neither the witness nor any person representing him will
make any statement to anyone (other than counsel) about the plans for or terms of the
interview. Likewise, the SDNY agrees to make no public comment about the matter during
this period. If an interview has not been concluded by August 14, this confidentiality
agreement will not bar any further public or private comments on the matter.
After an in-person interview:
-
If the witness completes an interview with U.S. law enforcement, both parties may confirm
publicly or privately that: "the witness has met with law enforcement authorities in the
United States and answered questions about matters under investigation. We will not
comment further." Further comment by the witness or any person representing or speaking
for him will void this agreement.
-
The content of the witness's statements to law enforcement as part of any interview arranged
pursuant to the MLA will only be used or disclosed as permitted under U.S. law, including in
connection with a criminal investigation or proceeding, as ordered or authorized by a court in
the United States, or as otherwise required by law.
Nothing in this agreement will bar any party from disclosing to a Court any communications related
to setting up or executing the interview or the contents of the interview.
From:
(CRM)
Sent: Tuesday, June 23, 2020 5:00 AM
To:
(USANYS)
is
)
EFTA00031515

=== Page 5 ===
Cc:
Subject: RE: Following up
Sounds good.
From:
(USANYS)
Sent: Monday, June 22, 2020 10:06 PM
To:
(CRM)
is
Cc:
Subject: RE: Following up
Thanks,
I am in the process of raising this internally on our end, but given recent events, and as I'm sure you can
imagine, it make take me a bit more time than usual to get back to you. I can tell you the conditions below are unlikely
to be acceptable to us as drafted, but provided it is in fact a rough outline, I am working on some proposed
modifications that folks here may be able to get comfortable with. I will circle back when I know more.
From:
CRM)
Sent: Monday, June 22, 2020 6:50 AM
To:
>;
(USANYS)
Cc:
Subject: Following up
Before this weekend's events, I was planning on writing an email proposing that you put together
some very specific terms for an in-person interview that we can share with the Home Office and the
police force which makes the first formal approach to the witness's solicitors. Most of the terms are
already noted in the MLA request: who will be present, where it will take place (UK), whether it will
be recorded or written, etc. What isn't covered is any kind of a description or agreement about
confidentiality. Absent this, a MLA police interview will get hung up like your efforts at a voluntary
interview.
This weekend's events, which are troubling on many levels, also provide an opportunity in this case.
Blackfords's and the witness's anger have been focused on your former USA's public statements.
They may now have some greater confidence that they can rely on any statements of confidentiality.
Or at least they can now save face by agreeing to an interview. In any event, given the history of
this, I think absent a mutual agreement on confidentiality, this matter will get mired in litigation, and
you may never get the interview.
Here is a rough outline of what might be acceptable on confidentiality. This may give you
heartburn, but I think it is the most expeditious way forward:
Prior to the in-person interview:
-
An agreement that for a period lasting no longer than eight (8) weeks, neither the witness nor
any person representing him will make any statement to anyone (other than counsel) about
the plans for or terms of the interview. Likewise, the USDOJ agrees to make no public
comment about the matter during this period. If an interview has not been concluded within
eight weeks, this confidentiality agreement will not bar any further public or private
comments on the matter.
After an in-person interview:
-
If the witness makes a statement, both parties may confirm publicly or privately that: "the
witness has provided a formal statement to law enforcement authorities in the United States
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=== Page 6 ===
about matters under investigation. Further comment would not be appropriate." Further
comment by the witness or any person representing or speaking for him will void this
agreement.
-
The content of witness's statement will be treated in the same manner as testimony taken
before a Federal Grand Jury under Fed.R.Crim.P. 6(e). Among other things, unless used in
connection with a criminal proceeding, required to be disclosed in connection with a criminal
proceeding, or otherwise ordered disclosed by a court in the United States, the content of the
statement will not be made public.
Nothing in this agreement will bar any party from disclosing to a Court any communications related
to setting up or executing the interview or the contents of the interview.
Putting something like this together will pave the way for getting the interview done.
Thanks,
U.S. Department of Justice Attaché
United States Embassy - London
U.K. Mobile:
From the U.S.: +44 788 581 2862
<Material Witness PA 4.02 Final - signed.pdf>
EFTA00031517


