# docs_fts_content

c1: EFTA00014169
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014169.pdf
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=== Page 1 ===
Event: Updated: Conference Call re: Epstein
Start Date: 2007-09-27 19:45:00 +0000
End Date: 2007-09-27 20:00:00 +0000
Organizer: Acosta, Alex (USAFLS)
Location: Alex's Office
Class: X-PERSONAL
Date Created: 2007-09-27 15:18:56 +0000
Date Modified: 2010-11-11 02:32:07 +0000
Priority: 5
DTSTAMP: 2007-09-27 15:18:50 +0000
Attendee:
EFTA00014169


c1: EFTA00016302
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016302.pdf
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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Jeff Pagliuca
"I aura Menninger"
Christian Everdell
, "Mark
S. Cohen"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - proposed redactions
Date: Fri, 04 Sep 2020 21:08:00 +0000
Attachments: 2020.08.24_JSP_Reply_Ltr_re._Modification_of_the_Protective_Order_(PROPOSED_RE
DACTIONS).pdf;
2020.08.24_JSP_Ltr_Submitting_Proposed_Redactions_Under_Seal_(PROPOSED_REDA
CTIONS).pdf
Good afternoon,
Pursuant to the Court's September 2, 2020 Order in the above-referenced case, the parties have conferred and agreed
upon proposed redactions to the defense letters dated August 24, 2020. Attached for the Court's consideration please
find the parties' agreed upon redactions to both letters.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00016302


c1: EFTA00015217
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015217.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: [EXTERNAL EMAIL] - RE: Maxwell discovery review
Date: Mon, 19 Oct 2020 02:49:21 +0000
Very sorry, but Maxwell's attorney just emailed to say that he needs to cancel this Tuesday's meeting. Would you
be available on Thursday or Friday of this week instead, please?
Thanks very much,
On Oct 16, 2020, at 11:28 AM,
) wrote:
Hi again,
We are confirmed for Tuesday 10/20. The attorney will be present with Maxwell for the review. The attorney is
scheduled to arrive at 8am, so the MDC asked that you two please arrive at 7:45 and ask for the Captain, so that the
Captain can go over the logistics with you.
Thanks very much again to you both, and please give me a call if any issues or questions come up.
From:
Sent: Thursday, October 15, 2020 4:56 PM
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - RE: Maxwell discovery review
Thanks so much to both of you. I've let the attorney know that Monday and Tuesday are both possibilities. I will let you
know when we have a new date and time confirmed.
From:
Sent: Thursday, October 15, 2020 4:52 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - RE: Maxwell discovery review
Monday or Tuesday preferably, thank you! Wednesday I'm unavailable. Thursday or Friday I can try to make it
work.
Thanks!
Special Agent
FBI - New York - SO-9
On Oct 15, 2020 4:49 PM,
wrote:
Free any day, just let me know when you need me.
EFTA00015217

=== Page 2 ===
On Oct 15, 2020 4:47 PM,
wrote:
Hi again,
Apologies for the last-minute change, but defense counsel has informed me that we need to cancel tomorrow's visit and
reschedule it for early next week. Are there any days next week when you would be available to go to the MDC instead?
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, October 15, 2020 3:11 PM
To:
Cc:
Subject: Maxwell discovery review
Thank you both so much for your assistance facilitating Ghislaine Maxwell's review of sensitive discovery materials. The
whole team is very grateful to you for your help.
I've informed
who is legal counsel at the MDC, that you two will be bringing the secure laptop to the
MDC tomorrow for Maxwell to review from 8am to 3pm.
indicated that the Captain will likely want to meet with
you when you arrive to discuss the logistics of where everyone will be while Maxwell is reviewing the material.
One thing to note: because Maxwell is represented by counsel, the FBI is not permitted to speak with her. So as a
reminder, please do not engage Maxwell in any conversation.
If you have any issues or questions at all, please do not hesitate to call me on my cellphone at
Thank you again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015218


c1: EFTA00017123
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017123.pdf
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=== Page 1 ===
From:
To:
Subject: RE: SHU Photos/Number of Steps
Date: Wed, 18 Sep 2019 20:05:54 +0000
It's downstairs in an envelope with your name on it. Thank you!
From
Sent: Wednesday, September 18, 2019 11:30 AM
To:
Subject: RE: SHU Photos/Number of Steps
Can you guys provide us with at least a 100GB hard drive so that FBI CART to download the material? Let me know when
and where I can pick up.
From:
Sent: Wednesday, September 18, 2019 10:15 AM
To:
ov>
Subject: SHU Photos/Number of Steps
Hey
I know FBI was taking photos of the SHU generally and measuring the number of steps from Epstein's cell to the guard
desk. Do you have those photos and can you provide them to us? Thank you.
Also, let us know if you need a hard drive from us for Thomas' phone.
Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00017123


c1: EFTA00016763
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016763.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: WSJ
Date: Sun, 28 Jul 2019 14:11:48 +0000
What Jail Is Like for Jeffrey Epstein
Now sleeping in the bottom bunk of a windowless 8-by-8-foot cell, the financier earlier was denied house arrest
at his sprawling Manhattan townhouse
Since his arrest on sex-trafficking charges, financier Jeffrey Epstein has spent much of his time in the bottom
bunk of a windowless 8-by-8-foot cell, according to the lawyer of his former cellmate.
The cell is in a wing of a federal jail in downtown Manhattan that is known as "the box" and has been the subject
of inmate complaints about mice and insect infestations, as well as standing water on the floor, according to
lawyers of inmates.
Mr. Epstein's roommate until Tuesday was Nicholas Tartaglione, a retired police officer accused of killing four
people, according to Mr. Tartaglione's lawyer, Bruce Barket.
"It is dark and it's disgusting," Mr. Barket said of the jail cell Messrs. Epstein and Tartaglione shared.
Mr. Epstein, 66 years old, was arrested July 6 and was later denied bail when a judge rejected his
lawyers' request that he be placed on house arrest in his sprawling Manhattan townhouse, which is valued at $77
million.
Mr. Epstein had built a fortune of more than half a billion dollars by cultivating his ties to rich and powerful
individuals. Prosecutors this month said they found a "piles of cash" and dozens of diamonds in a locked safe at
his New York mansion.
The financier has pleaded not guilty to sex-trafficking charges stemming from what prosecutors allege was a
yearslong scheme from 2002 to 2005 to recruit and sexually abuse dozens of girls.
Following his arrest, he has mostly been at the Manhattan jail, which is known as the Metropolitan Correctional
Center. He was moved to a suicide-watch unit after being found unconscious in his cell Tuesdaymorning,
according to people familiar with the matter.
EFTA00016763

=== Page 2 ===
A lawyer for Mr. Epstein declined to comment. Mr. Tartaglione was interviewed in connection with Mr. Epstein's
injuries but had no part in them, Mr. Barket said.
The jail houses 774 inmates, most of them awaiting trial. It has been home to such high-profile inmates
as Mexican drug lord Joaquín "El Chapo" Guzmán, who was sentenced earlier this month to life in prison.
Federal records show that the current occupants include Cesar Sayoc, who pleaded guilty to sending bombs to
prominent Democrats and is awaiting sentencing, and Sayfullo Saipov, accused of killing eight people by driving
a truck on to a Manhattan bike path. Mr. Saipov has pleaded not guilty.
Mr. Epstein and other inmates are allowed to leave their cells for an hour of recreation each day, as well as
meetings with lawyers, according to a correction officer.
Mr. Barket said that Messrs. Tartaglione and Epstein were friendly and frequently spoke while they were
bunkmates. Mr. Tartaglione was arrested in 2016 for killing four people in Chester, N.Y. He has pleaded not
guilty.
Mr. Tartaglione's lawyer has been a vocal critic of the conditions in the jail, filing complaints to correction
officials about rodents and bugs.
Lawyers for Mr. Guzman blamed frigid temperatures, lack of clean blankets and contaminated water at the jail as
reasons for their client's failing health.
Serene Gregg, a case worker at the Metropolitan Correctional Center and president of the correction workers'
union chapter, said there are mice and broken toilets and sinks.
Representatives for the Federal Bureau of Prisons, which manages the Metropolitan Correctional Center, didn't
respond to questions about the conditions there.
"There is no worse place you can find yourself," Mr. Barket said.
Sent from my iPhone
EFTA00016764


c1: EFTA00015561
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015561.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: Draft SW for JE phone & ipad
Date: Sun, 14 Jul 2019 17:17:54 +0000
Importance: Normal
Attachments: SW_for_JE_Phone_&_iPad.docx
and
Attached for review is a draft search warrant application for the phone and ipad that were seized from Epstein on the day
of his arrest. Happy to discuss.
Thanks,
EFTA00015561


c1: EFTA00015913
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015913.pdf
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=== Page 1 ===
From:
To:
)"
Cc:
)"
(USANYS)"
Subject: Ghislaine Maxwell 02879-509
Date: Wed, 30 Dec 2020 18:15:39 +0000
MDC Legal continues to provide inaccurate information.
Contrary to the information provided to you as recited in your email of 12/29-
"MDC legal counsel confirmed that no staff member has ever directed
Ms. Maxwell to remain in a particular location within her isolation cell.
They confirmed that staff understand that no such directions should be given."
last evening (12/29), Ms. Maxwell was instructed by guards not to stand
on either corner of her isolation cell, not to stand to the left or right of the toilet and sink,
and not to stand within 2.5 feet of the door to the cell.
She was told that if she did not comply with this directive, she would receive a disciplinary sanction.
In addition, she is not receiving food designated on the menu.
Further, the discovery disc provided does not work on the MDC computer; and the computer
reports multiple errors indicating it cannot accommodate disc.
Consequently, a replacement disc and/or replacement computer is required.
Please let us know of the status of hard drive containing complete production;
its immediate production could eliminate the disc issue.
Your assistance is appreciated.
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of
that may be confidential and/or privileged.
EFTA00015913

=== Page 2 ===
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00015914


c1: EFTA00015058
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015058.pdf
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=== Page 1 ===
From: jeffrey epstein <jeevacation@gmail.com>
Date: 9 May 2011 at 17:09:53 GMT-7
To:
Subject: Re: NYC
I'm in Paris
Sent from my iPad
On May 10, 2011, at 1:20 AM,
wrote:
Hey J,
I'm coming to NYC this Thurs and leaving Mon, I wondered if
there was any chance you had a corner I could stay in?
Totally cool if not, either way I want to see you if you are
going to be there.
Let me know
EFTA00015058

=== Page 2 ===
XXXX


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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014888.pdf
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=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Anticipated order of witnesses
Date: Sun, 28 Nov 2021 02:01:07 +0000
Attachments: 2021-11-27,_GM,_Government_anticipated_witness_order_[final].pdf
Chambers,
Attached please find a letter regarding the Government's anticipated order of witnesses. As explained in the letter, the
Government requests that this letter be filed under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00014888


c1: EFTA00014664
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014664.pdf
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=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
)"
Subject: RE: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Wed, 12 May 2021 22:15:01 +0000
Attachments: 2021.05.11, GM,_scheduling_order.pdf
The Court has issued a scheduling order for the trial (attached). Jury selection will occur during the week of November
15th, and the trial will begin on November 29th.
Thanks,
From:
Sent: Friday, May 7, 2021 2:14 PM
To:
)
Cc
is
(USANYS)
is
)
Subject: Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Everyone is all clear for November/December.
Sent from my iPhone
On May 7, 2021, at 1:27 PM,
)
wrote:
Hi
Following up on our conversation yesterday, please let us know if there are any scheduling conflicts we should be aware
of. Our letter to the Court regarding scheduling is due on Monday.
Thanks very much,
From:
Sent: Thursday, May 6, 2021 12:57 PM
To:
Cc: Brittany Henderson
i
(USANYS)
is
)
Subject: Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
EFTA00014664

=== Page 2 ===
I can talk from now until 3.
Sent from my iPhone
On May 6, 2021, at 12:53 PM,
wrote:
Following up on this, do you have a few minutes this afternoon or tomorrow for a few scheduling questions? We are
working on a proposal to the Court regarding a potential trial date, but wanted to consult with you to make sure we
weren't proposing dates when your clients were not available.
Thanks,
From:
Sent: Monday. May 3. 2021 6:23 PM
To:
Cc:
)
is
(USANYS)
;
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Please see the attached order regarding the trial date in this case. We'll update you when we have more information.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00014665


c1: EFTA00015024
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015024.pdf
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=== Page 1 ===
From:
"
To:
"
)"
Subject: Epstein
Date: Tue, 04 Feb 2020 00:40:15 +0000
Importance: Normal
Attachments: unnamed
EFTA00015024


c1: EFTA00015837
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015837.pdf
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=== Page 1 ===
Event: Call on Epstein/Maxwell Documents
Start Date: 2020-07-23 16:00:00 +0000
End Date: 2020-07-23 16:30:00 +0000
Organizer:
(USANYS)
Location:
Conf. Id 758788
Class: X-PERSONAL
Date Created: 2020-07-22 20:23:04 +0000
Date Modified: 2020-07-22 20:23:04 +0000
Priority: 5
DTSTAMP: 2020-07-22 20:06:02 +0000
Attendee:
(ODAG)
i
(USANYS)
Alarm: Display the following message 15m before start
Reminder
EFTA00015837


c1: EFTA00016922
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c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016922.pdf
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=== Page 1 ===
From:
To:
Subject: Accepted:
proffer (re abuse)
Date: Wed, 27 Nov 2019 16:46:05 +0000
Importance: Normal
Attachments: unnamed
EFTA00016922


c1: EFTA00014901
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014901.pdf
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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 15:16:37 +0000
I second that - go team.
From:
Sent: Monday, November 29, 2021 9:33 AM
To:
Cc:
Subject: FW: United States V. Ghislaine Maxwell --
opens
Good luck ladies! I have no doubt you will rock it.
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS
>; USANYS-CRIMINAL PARALEGALS
>; USANYS-INVESTIGATORS
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
EFTA00014901


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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
DEPUBLIK ERREIGN
DIE GÜLTIGKEIT DIESES REISEPASSES ENDET AM
MPEMA OSTERSEN 100
LA VALIDITE DE CE PASSEPORT EXPIRE LE
THE VALIDITY OF THIS PASSPORT EXPIRES
21. Mai 1987
Wion
Behörde
Autorité
Authority
Ort und Datum
21. Mai 982
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


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=== Page 1 ===
From:
To:
Subject:
Date: Thu, 08 Apr 2021 18:20:05 +0000
Embedded: Re:_Follow-up.msg
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00015752


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=== Page 1 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES ROBERTSON,
Plaintiffs,
V.
Civil Action No. 1:17-cv-03956-PGG
FEDERAL BUREAU OF INVESTIGATION,
Defendant.
DECLARATION OF MICHAEL G. SEIDEL
I, Michael G. Seidel, declare as follows:
(1)
I am the Section Chief of the Record/Information Dissemination Section
("RIDS"), Information Management Division ("IMD"), Federal Bureau of Investigation ("FBI"),
Winchester, Virginia. I joined the FBI in September 2011, and prior to my current position, I
was the Acting Section Chief from May 26, 2020 to July 26, 2020; Assistant Section Chief of
RIDS from June 2016 to May 25, 2020; Unit Chief, RIDS Litigation Support Unit from
November 2012 to June 2016; and an Assistant General Counsel, FBI Office of General Counsel,
Freedom of Information Act ("FOIA") Litigation Unit, from September 2011 to November 2012.
In those capacities, I had management oversight or agency counsel responsibility for FBI FOIA
and Privacy Act ("FOIPA") litigation cases nationwide. Prior to my joining the FBI, I served as
a Senior Attorney, U.S. Drug Enforcement Administration ("DEA") from September 2006 to
September 2011, where among myriad legal responsibilities, I advised on FOIPA matters and
served as agency counsel representing the DEA in FOIPA suits nationwide. I also served as a
U.S. Army Judge Advocate General's Corps Officer in various assignments from 1994 to
1
EFTA00015219

=== Page 2 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
September 2006 culminating in my assignment as Chief, General Litigation Branch, U.S. Army
Litigation Division where I oversaw FOIPA litigation for the U.S. Army. I am an attorney
registered in the State of Ohio and the District of Columbia.
(2)
In my official capacity as Section Chief of RIDS, I supervise approximately 237
FBI employees, supported by approximately 91 contractors, who staff a total of ten (10) FBI
Headquarters ("FBIHQ") units and two (2) field operational service center units whose collective
mission is to effectively plan, develop, direct, and manage responses to requests for access to
FBI records and information pursuant to the FOIA as amended by the OPEN Government Act of
2007, the OPEN FOIA Act of 2009, and the FOIA Improvement Act of 2016; the Privacy Act of
1974; Executive Order 13,526; Presidential, Attorney General, and FBI policies and procedures;
judicial decisions; and Presidential and Congressional directives. The statements contained in
this declaration are based upon my personal knowledge, upon information provided to me in my
official capacity, and upon conclusions and determinations reached and made in accordance
therewith.
(3)
Because of the nature of my official duties, I am familiar with the procedures
followed by the FBI in responding to requests for information from its files pursuant to the
provisions of the FOIA, 5 U.S.C. § 552, and the Privacy Act of 1974, 5 U.S.C. § 552a.
Specifically, I am aware of the FBI's handling of Plaintiff James Robertson's FOIA request for
records related to the FBI's investigation and prosecution of financier Jeffrey Edward Epstein.
In response to Plaintiff's request, the FBI processed on a document-by-document basis a total of
11,571 pages of responsive records. Of these pages, the FBI released 181 pages in full, released
1,051 pages in part, and withheld 10,339 pages in full for the following reasons: the information
in those pages was exempt from disclosure pursuant to one or more applicable FOIA
2
EFTA00015220

=== Page 3 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
Exemption(s); the pages were found to be duplicative of other pages accounted for elsewhere in
the FBI's production; and/or the pages are sealed pursuant to United States Court order and thus
unavailable for release through the FOIA. In addition to the 11,571 processed pages, the FBI
also categorically withheld additional records pursuant to Exemption 7(A). See infra FN 7.
(4)
In accordance with Vaughn V. Rosen, 424 F.2d 820 (D.C. Cir. 1973), this
declaration is being submitted in support of Defendant's motion for summary judgment, and
provides the Court with a summary of the administrative history of Plaintiff's request; the
procedures used to search for, review, and process responsive records; the FBI's justification for
withholding information in part or in full pursuant to FOIA Exemptions 3, 5, 6, 7(A), 7(C), 7(D),
and 7(E), 5 U.S.C. §§ 552(b)(3), (b)(5), (b)(6), (b)(7)(A), (b)(7)(C), (b)(7)(D), and (b)(7)(E); and
the FBI's procedures for reviewing records that were categorically exempt pursuant to
Exemption (7)(A).
BACKGROUND INFORMATION CONCERNING JEFFREY EDWARD EPSTEIN
(5)
In June 2008, Jeffrey Epstein pled guilty to a criminal charge of procuring
prostitution of a minor. Epstein served 13 months of his 18-month sentence. On July 2, 2019,
Jeffrey Epstein was indicted by a federal grand jury in the United States District Court for the
Southern District of New York on 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. United States V. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.), Dkt. No. 2. Based on the
indictment, Epstein was arrested by federal authorities. Epstein later died on August 10, 2019, at
the Metropolitan Correctional Center, in New York, while the federal charges were pending.
United States V. Epstein, No. 19 Cr. 490 (RMB) (S.D.N.Y.), Dkt. No. 52.
ADMINISTRATIVE HISTORY OF PLAINTIFFS' REQUEST
3
EFTA00015221

=== Page 4 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(6)
By electronic FOIA ("eFOIA")¹ dated April 20, 2017, Plaintiff Robertson
submitted a FOIPA request to the FBI seeking "all documents relating to the FBI's investigation
and prosecution of financier Jeffrey Edward Epstein
Additionally,
he
requested
a
fee
waiver and expedited processing. (Ex. A.)
(7)
By letter dated April 28, 2017, the FBI acknowledged receipt of Plaintiff's FOIA
request, and notified Plaintiff it had assigned his request FBI FOIPA Request Number 1372398-
000. The FBI informed Plaintiff that, because he requested information on one or more third
party individuals, the FBI would neither confirm nor deny the existence of such records pursuant
to FOIA Exemptions 6 and 7(C), 5 U.S.C. § 552(b)(6) and (b)(7)(C). The FBI's response
explained that the mere acknowledgement of the existence of FBI records on third party
individuals could reasonably be expected to constitute an unwarranted invasion of personal
privacy. Additionally, the FBI advised it was closing Plaintiffs' request. The FBI instructed
Plaintiff to visit www.fbi.gov, select "Services," "Information Management," and "Freedom of
Information/Privacy Act" for more information about making requests for records on third party
individuals (living or deceased). Finally, the FBI informed Plaintiffs they could appeal the FBI's
response to the DOJ, Office of Information Policy ("OIP") within ninety (90) days of its letter,
contact the FBI's public liaison, and or seek dispute resolution services by contacting the Office
of Government Information Services ("OGIS"). (Ex. B.)
(8)
On August 28, 2017, Plaintiffs, through counsel, filed their First Amended
Complaint with the United States District Court for the Southern District of New York.2 (ECF
1 An eFOIA is an electronic means by which requesters can submit FOIA requests to the FBI,
online, through the FBI's public website, www.FBI.gov.
2 Plaintiff Radar Online had filed a Complaint on May 25, 2017. After the FBI pointed out that
Radar Online was not a proper Plaintiff in this case, Plaintiff James Robertson was added as a
Plaintiff in the First Amended Complaint.
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No. 12.)
(9)
By letter dated October 11, 2017, the FBI released responsive records to
Plaintiffs. The FBI advised that it had reviewed 296 pages of records, released 38 pages of
records in full or part and withheld the remaining pages in full. Information was withheld
pursuant to FOIA Exemptions 3, 6, 7(A), 7(C), 7(D), and 7(E). (Ex. C.)
(10) By letter dated November 1, 2017, the FBI released additional responsive records
to Plaintiffs. The FBI advised it reviewed 527 pages of records and released 25 pages of records
in full or part, with information withheld pursuant to FOIA Exemptions 3, 6, 7(A), 7(C), 7(D),
and 7(E). (Ex. D.)
(11) By letter dated December 1, 2017, the FBI released additional responsive records
to Plaintiffs. The FBI advised it reviewed 562 pages of records and released 94 pages of records
in full or part, with information withheld pursuant to FOIA Exemptions 3, 6, 7(C), 7(D), and
7(E). (Ex. E.)
(12) By letter dated January 2, 2018, the FBI released additional responsive records to
Plaintiffs. The FBI advised it reviewed 556 pages of records and released 38 pages of records in
full or part, with information withheld pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex.
F.)
(13) By letter dated February 1, 2018, the FBI advised it had withheld an additional
525 pages in full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(E). (Ex. G.)
(14)
By letter dated March 1, 2018, the FBI advised that it had reviewed 527
pages of records and released eight (8) pages of records in full or part, with
information withheld pursuant to FOIA Exemptions 3, 5, 6, 7(C), 7(D), and 7(E).
(Ex. H.)
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=== Page 6 ===
Author: CGM
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(15) By letter dated March 30, 2018, the FBI advised that it had withheld 520 pages in
full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex. I.)
(16) By letter dated May 1, 2018, the FBI advised that it withheld an additional 567
pages in full pursuant to FOIA Exemptions 3, 6, 7(C), 7(D), and 7(E). (Ex. J.)
(17) By letter dated June 1, 2018, the FBI advised that it withheld 574 pages of records
in full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex. K.)
(18) By letter dated July 2, 2018, the FBI advised that it withheld 547 pages of records
in full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex. L.)
(19) By letter dated August 1, 2018, the FBI advised it withheld 526 pages of records
in full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex. M.)
(20) By letter dated August 31, 2018, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 508 pages of records, released 160 pages of records in full or part,
with withheld the remaining pages in full. Information was withheld pursuant to FOIA
Exemptions 3, 5, 6, 7(C), 7(D), and 7(E). (Ex. N.)
(21) By letter dated September 28, 2018, the FBI advised it withheld 532 pages of
records in full pursuant to FOIA Exemptions 3, 6, 7(C), and 7(D). (Ex. 0.)
(22) By letter dated October 31, 2018, the FBI released responsive records to
Plaintiffs. The FBI advised it reviewed 500 pages of records and released 174 pages of records
in full or part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), 7(D),
and 7(E). (Ex. P.)
(23) By letter dated November 30, 2018, the FBI released responsive records to
Plaintiffs. The FBI advised it reviewed 518 pages of records and released seven (7) pages of
records in full or part, with certain information withheld pursuant to FOIA Exemptions 3, 6, and
6
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=== Page 7 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
7(C). (Ex. Q.)
(24) By letter dated December 28, 2018, the FBI released responsive records to
Plaintiffs. The FBI advised it reviewed 519 pages of records and released four (4) pages of
records in full or part, with certain information withheld pursuant to FOIA Exemptions 3, 6, and
7(C). (Ex. R.)
(25) By letter dated March 1, 2019³, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 574 pages of records and released 209 pages of records in full or
part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), and 7(E). (Ex.
S.)
(26) By letter dated April 1, 2019, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 515 pages of records and released 232 pages of records in full or
part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), and 7(E). (Ex.
T.)
(27) By letter dated May 1, 2019, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 540 pages of records and released 65 pages of records in full or
part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), 7(D), and 7(E).
(Ex. U.)
(28) By letter dated May 31, 2019, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 519 pages of records and released 12 pages of records in full or
part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), 7(D), and 7(E).
(Ex. V.)
3 No production occurred in January through March 2019, because of the lapse in appropriations
funding for the Department of Justice.
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=== Page 8 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(29) By letter dated June 28, 2019, the FBI released responsive records to Plaintiffs.
The FBI advised it reviewed 527 pages of records and released 107 pages of records in full or
part, with certain information withheld pursuant to FOIA Exemptions 3, 6, 7(C), 7(D), and 7(E).
(Ex. W.)
(30) In a series of letters sent between August 1, 2019, and December 31, 2019, the
FBI informed Plaintiffs the material they requested was located in an investigative file exempt
from disclosure pursuant to 5 U.S.C. $ 552(b)(7)(A).4 The FBI categorically reviewed⁵ the
remaining responsive documents, at a rate of no less than 500 per month, and cited all applicable
underlying exemptions. The FBI withheld in full all remaining responsive records pursuant to
FOIA Exemption 7(A). Information in those records was also withheld pursuant to FOIA
Exemptions 3, 5, 6, 7(B), 7(C), 7(D), and 7(E).⁶ (Exs. X, Y, Z, AA, BB, CC.)
(31) By letter dated January 31, 2020, the FBI released additional responsive records
4 Jeffrey Epstein was arrested on July 6, 2019, on federal charges for the sex trafficking of
minors. RIDS reached out to an Assistant United States Attorney in SDNY, who confirmed that
additional release of responsive material could negatively impact the pending prosecution. With
this new development-a re-opened investigation-the further release of any responsive records
was now reasonably anticipated to cause harm to the ongoing enforcement proceedings; thus,
Exemption 7(A) became a properly asserted exemption claim over all previously protected
information.
5 During a categorical review, the FBI reviews each document and determines if the release of
the documents would interfere with ongoing law enforcement proceedings. If processing a
document for release could interfere with any law enforcement proceeding, the FOIA analyst
will assert Exemption 7(A) and all underlying exemptions. This review process is explained in
detail in 11 65-75 infra.
6 The FBI began processing documents in response to Plaintiffs' request long before Mr. Epstein
was arrested in 2019. When Mr. Epstein's arrest and the ongoing investigation became public in
July 2019, the FBI began to assert Exemption 7(B) given that (1) a trial or adjudication was
pending or truly imminent and (2) it was more probable than not that disclosure of the records
would seriously interfere with the fairness of those proceedings. Mr. Epstein's death on August
10, 2019, arguably negated the application of Exemption 7(B). However, the records withheld
pursuant to Exemption 7(B) were additionally withheld pursuant to Exemptions 3, 6, 7(A), 7(C),
and 7(D), and remain properly withheld despite Mr. Epstein's death.
8
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=== Page 9 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
to Plaintiffs. In particular, the FBI released 46 pages of records in full or part, with certain
information withheld pursuant to FOIA Exemptions 3, 6, 7(A), 7(C), 7(D), and 7(E). (Ex. DD.)
THE FBI'S CENTRAL RECORDS SYSTEM
(32) The Central Records System ("CRS") is an extensive system of records consisting
of applicant, investigative, intelligence, personnel, administrative, and general files compiled and
maintained by the FBI in the course of fulfilling its integrated missions and functions as a law
enforcement, counterterrorism, and intelligence agency to include performance of administrative
and personnel functions. The CRS spans the entire FBI organization and encompasses the
records of FBI Headquarters ("FBIHQ"), FBI Field Offices, and FBI Legal Attaché Offices
("Legats") worldwide.
(33) The CRS consists of a numerical sequence of files, called FBI "classifications,"
which are organized according to designated subject categories. The broad array of CRS file
classification categories include types of criminal conduct and investigations conducted by the
FBI, as well as categorical subjects pertaining to counterterrorism, intelligence,
counterintelligence, personnel, and administrative matters. For identification and retrieval
purposes across the FBI, when a case file is opened, it is assigned a Universal Case File Number
("UCFN") consisting of three sequential components: (a) the CRS file classification number, (b)
the abbreviation of the FBI Office of Origin ("00") initiating the file, and (c) the assigned
individual case file number for that particular subject matter.⁷ Within each case file, pertinent
documents of interest are "serialized," or assigned a document number in the order which the
7 For example, in a fictitious file number of "11Z-HQ-56789;" the "11Z" component indicates
the file classification, "HQ" indicates that FBI Headquarters is the FBI 00 of the file, and
"56789"is the assigned case specific file number.
9
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=== Page 10 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
document is added to the file, typically in chronological order.
THE CRS GENERAL INDICES AND INDEXING
(34) The general indices to the CRS are the index or "key" to locating records within
the enormous amount of information contained in the CRS. The CRS is indexed in a manner
which meets the FBI's investigative needs and priorities and allows FBI personnel to reasonably
and adequately locate pertinent files in the performance of their law enforcement duties. The
general indices are arranged in alphabetical order and comprise an index on a variety of subject
matters to include individuals, organizations, events, or other subjects of investigative interest
that are indexed for future retrieval. The entries in the general indices fall into two category
types:
A. Main entry. A main index entry is a created for each individual or non-individual
that is the subject or focus of an investigation. The main subject(s) are identified
in the case title of most documents in a file.
B. Reference entry. A reference index entry is created for individuals or non-
individuals associated with the case but are not the main subject(s) or focus of an
investigation. Reference subjects are typically not identified in the case title of a
file.
(35) FBI employees may index information in the CRS by individual (persons), by
organization (organizational entities, places, and things), and by event (e.g., a terrorist attack or
bank robbery). Indexing information in the CRS is done at the discretion of FBI investigators
when information is deemed of sufficient significance to warrant indexing for future retrieval.
Accordingly, the FBI does not index every individual name or other subject matter in the general
indices.
AUTOMATED CASE SUPPORT
(36) Automated Case Support ("ACS") was an electronic, integrated case management
system that became effective for FBIHQ and all FBI Field Offices and Legats on October 1,
10
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=== Page 11 ===
Author: CGM
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
1995. As part of the ACS implementation process, over 105 million CRS records were
converted from automated systems previously utilized by the FBI into a single, consolidated case
management system accessible by all FBI offices. ACS had an operational purpose and design
to enable the FBI to locate, retrieve, and maintain information in its files in the performance of
its myriad missions and functions.8
(37) The Universal Index ("UNI") was the automated index of the CRS and provided
all offices of the FBI a centralized, electronic means of indexing pertinent investigative
information to FBI files for future retrieval via index searching. Individual names were recorded
with applicable identifying information such as date of birth, race, sex, locality, Social Security
Number, address, and/or date of an event. Moreover, ACS implementation built upon and
incorporated prior automated FBI indices; therefore, a search employing the UNI application of
ACS encompassed data that was already indexed into the prior automated systems superseded by
ACS. As such, a UNI index search in ACS was capable of locating FBI records created before
its 1995 FBI-wide implementation in both paper and electronic format.9
ACS AND SENTINEL
(38) Sentinel is the FBI's next generation case management system that became
effective FBI-wide on July 1, 2012. Sentinel provides a web-based interface to FBI users, and it
includes the same automated applications that were utilized in ACS. After July 1, 2012, all FBI
8 ACS was, and the next generation Sentinel system is, relied upon by the FBI daily to fulfill
essential functions such as conducting criminal, counterterrorism, and national security
investigations; background investigations; citizenship and employment queries, and security
screening, to include Presidential protection.
9 Older CRS records that were not indexed into UNI as a result of the 1995 ACS consolidation
remain searchable by manual review of index cards, known as the "manual indices."
11
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=== Page 12 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
generated records are created electronically in case files via Sentinel; however, Sentinel did not
replace ACS and its relevance as an important FBI search mechanism. Just as pertinent
information was indexed into UNI for records generated in ACS before July 1, 2012, when a
record is generated in Sentinel, information is indexed for future retrieval.
(39) On August 1, 2018, the ACS case management system was decommissioned and
ACS data was migrated into Sentinel including the ACS indices data and digitized investigative
records formerly available in ACS. Moreover, Sentinel retains the index search methodology
and function whereby the CRS is queried via Sentinel for pertinent indexed main or reference
entries in case files. All CRS index data from the UNI application previously searched via ACS
is now searched through the "ACS Search" function within Sentinel.
(40) Upon receipt of FOIPA requests where the subject matter predates the
implementation of Sentinel, RIDS predominately begins its FOIPA searching efforts by
conducting index searches via the "ACS Search" function in Sentinel. RIDS then builds on its
ACS index search by conducting an index search of Sentinel records to ensure it captures all
relevant data indexed after the implementation of Sentinel. The CRS automated indices,
available within Sentinel and the ACS search function in Sentinel, in most cases represent the
most reasonable means for the FBI to locate records potentially responsive to FOIPA requests.
This is because these automated indices offer access to a comprehensive, agency-wide set of
indexed data on a wide variety of investigative and administrative subjects. Currently, these
automated indices consist of millions of searchable records and are updated daily with material
newly indexed in Sentinel.
(41) However, the location of records indexed to the subject of a FOIPA request does
not automatically mean the indexed records are responsive to the subject. Index searches are the
12
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=== Page 13 ===
Author: CGM
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
means by which potentially responsive records are located, but ultimately, a FOIPA analyst must
consider potentially responsive indexed records against the specific parameters of individual
requests. Responsiveness determinations are made once indexed records are gathered, analyzed,
and sorted by FOIPA analysts, who then review the records to determine which are responsive to
an individual request.
ADEQUACY OF SEARCH
(42) Scope of Search and Results. RIDS conducted a search reasonably calculated to
locate records responsive to Plaintiffs' request, specifically "documents relating to FBI's
investigation and prosecution of financier Jeffrey Edward Epstein
"
Prior to conducting a
search of the CRS, and particularly in matters of heightened public interest, RIDS typically
conducts a preliminary search of the FOIA Document Processing System ("FDPS") to determine
if a subject has been previously requested or is currently being processed in response to another
request. This helps to avoid duplication of efforts and is an efficient means of getting more
records to more requesters, while conserving RIDS limited resources. As a result of the FBI's
search of FDPS, RIDS located documents responsive to Plaintiffs' request in a first-party FOIPA
request made on behalf of Jeffrey Epstein, which had been identified by an index search of the
CRS. The documents responsive to Epstein's FOIPA were also responsive to the Plaintiffs'
request; they had already been retrieved at the time RIDS did its inquiry and processing of those
records was underway. To ensure all responsive records were located from within the CRS,
RIDS conducted a supplemental search utilizing the search term "Jeffrey Epstein", and no
additional records were located responsive to Plaintiffs' request.
10 The first-party FOIPA request sought main and cross-referenced records from January 1, 2000,
to November 25, 2012, on Jeffrey Epstein.
13
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=== Page 14 ===
Author: CGM
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
JUSTIFICATION FOR NONDISCLOSURE UNDER THE FOIA
(43) The FBI began processing documents in response to Plaintiffs' request long
before Mr. Epstein was arrested in 2019. Therefore, the FBI initially processed the records
without reference to an ongoing investigation. After Mr. Epstein's arrest and the ongoing
investigation became public in July 2019, the FBI began to assert Exemption 7(A) with respect
to withheld information. In addition, the FBI asserted Exemption 7(A) over all information that
had been withheld under other exemptions prior to that date, as noted in footnote 5, supra. Thus,
while Exemption 7(A) was not included on the face of the documents that were processed and
released in part prior to July 2019, it has been added to the index for all such documents. See
Exhibit EE. As to those records that warranted categorical denial after the arrest of Mr. Epstein
in July 2019, the review is more fully explained in paragraphs 67 through 79, infra.
(44) The FBI processed all documents responsive to Plaintiffs' request to achieve
maximum disclosure consistent with the access provisions of the FOIA. Every effort was made
to provide Plaintiffs with all material in the public domain and with all reasonably segregable,
non-exempt information. The FBI did not withhold any reasonably segregable, nonexempt
portions from Plaintiffs. Further description of the information withheld, beyond what is
provided in this declaration, could identify the actual exempt information protected by the FBI.
The FBI Bates-stamped all pages that it processed prior to July 2019 consecutively as "03956-1
through 03956-11571." These records are referred to in this declaration collectively as the
Bates-stamped or Bates-numbered records. 11 On the pages released in full or in part, these
11 In contrast, records processed after July 2019 were not Bates-stamped, as those records were
subject to categorical withholding per Exemption 7(A). Thus, when I refer to the Bates-
numbered records, I am not including the records processed after July 2019 that were subject to
categorical withholding. Those records, which will sometimes be referred to collectively as the
categorically withheld records, are more fully addressed in 67 through 79, infra.
14
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=== Page 15 ===
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
numbers are typically located at the bottom of each page. Attached to this declaration as Exhibit
EE is an index of the Bates-stamped records that have been withheld in full or in part, with an
explanation of the basis for each withholding.¹²
(45) Additionally, with respect to the Bates-stamped records, the FBI further
categorized its application of exemptions to provide additional detail regarding the nature of the
information withheld. Specifically, the FBI applied numerical codes that coincide with various
categories of exempt information. These coded categories are provided to aid the Court's and
Plaintiffs' review of the FBI's explanations of the FOIA exemptions it has asserted to withhold
the material. The uses of these codes, together with the information provided in this declaration,
demonstrate that all material withheld by the FBI is exempt from disclosure pursuant to the cited
FOIA exemptions, or is so intertwined with protected material that segregation is not possible
without revealing the underlying protected material.
(46) Each instance of information withheld pursuant to a FOIA Exemption is
accompanied by a coded designation that corresponds to the categories listed below. For
example, if "(b)(7)(C)-1" appears on a document, the "(b)(7)(C)" designation refers to FOIA
Exemption 7(C) protecting against unwarranted invasions of personal privacy. The numerical
designation of "1" following the "(b)(7)(C)" narrows the main category into a more specific
subcategory, such as "Names and Identifying Information of Third Parties of Investigative
Interest."
12 FBI provided Plaintiffs a draft copy of the index. After the index was shared with Plaintiffs,
FBI discovered a number of documents that were stamped with previously-used Bates numbers.
As a result, the documents that were previously Bates-stamped 03956-10980 through 03956-
11029 have been renumbered to 03956-11522 through 03956-11571. Exhibit EE has been edited
to reflect the corrected Bates-numbers.
15
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=== Page 16 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(47) Listed below are the categories used to explain the FOIA exemptions the FBI
asserted to withhold information:
SUMMARY OF EXEMPTION JUSTIFICATION CATEGORIES
CODED
INFORMATION WITHHELD
CATEGORIES
Exemption 3
Information Protected by Statute
(b)(3)-1
Child Victims' and Child Witnesses' Rights Act, 18 U.S.C. § 3509
(b)(3)-2
Grand Jury Information - - Federal Rule of Criminal Procedure 6(e)
(b)(3)-3
Juvenile Justice and Delinquency Act 18 U.S.C. § 5038
Exemption 5
Privileged Information
(b)(5)-1
Deliberative Process Privilege
(b)(5)-2
Attorney Work Product
Exemption 7(A)
Pending Law Enforcement Proceedings
(b)(7)(A)-113
Information Which, if Disclosed, Could Reasonably be Expected to
Interfere with Pending Law Enforcement Proceedings
Exemptions 6 & 7(C)
Unwarranted/Clearly Unwarranted Invasion of Personal Privacy
(b)(6)-1 and (b)(7)(C)-1
Names and/or Identifying Information of Third Parties of Investigative
Interest
(b)(6)-2 and (b)(7)(C)-2
Names and/or Identifying Information of FBI Special Agents and
Victim Specialists
(b)(6)-3 and (b)(7)(C)-3
Names and/or Identifying Information Regarding a Third Party Victim
(b)(6)-4 and (b)(7)(C)-4
Names and/or Identifying Information of Local Law Enforcement
Personnel
Names and/or Identifying Information of Third Parties Merely
(b)(6)-5 and (b)(7)(C)-5
Mentioned
(b)(6)-6 and (b)(7)(C)-6
Names and/or Identifying Information of Non-FBI Federal Government
Personnel
(b)(6)-7 and (b)(7)(C)-7
Names and/or Identifying Information of Local Government Personnel
(Non-Law Enforcement and State)
(b)(6)-8 and (b)(7)(C)-8
Names and/or Identifying Information of Third Parties who Provided
Information
Exemption 7(D)
Confidential Source Information
(b)(7)(D)-1
Names, Identifying Data and/or Information Provided by Individuals
Under an Implied Assurance of Confidentiality
(b)(7)(D)-2
Names, Identifying Data and/or Information Provided by Individuals
Under an Expressed Assurance of Confidentiality
(b)(7)(D)-3
Foreign Government Agency Information Under Implied
Confidentiality
13 As explained further herein, due to the current ongoing investigation, Exemption 7(A) must
now be asserted to protect all redacted information, including the information redacted prior to
the July 6, 2019, arrest of Mr. Epstein.
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=== Page 17 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(b)(7)(D)-4
Information Provided by a Local Law Enforcement Agency
Exemption 7(E)
Law Enforcement Techniques and Procedures
(b)(7)(E)-1
Collection/Analysis of Information
(b)(7)(E)-3
Sensitive File Numbers
(b)(7)(E)-4
Dates/Types of Investigations
(b)(7)(E)-5
Information Regarding Targets, Dates, and Scope of Surveillance
(b)(7)(E)-6
Statistical Information Contained in Effectiveness Rating FD-515
(b)(7)(E)-7
Database Identifiers/Printouts
(b)(7)(E)-9
Monetary Payments/Funding for Investigative Purposes
EXEMPTION 3- - INFORMATION PROTECTED BY STATUTE
(48) 5 U.S.C. § 552 (b)(3) exempts from disclosure information which is:
specifically exempted from disclosure by statute
if that statute (A)(i) requires
that the matters be withheld from the public in such a manner as to leave no
discretion on the issue; or (A)(ii) establishes particular criteria for withholding or
refers to particular types of matters to be withheld; and (B) if enacted after the date
of enactment of the Open FOIA Act of 2009, specifically cites to this paragraph.
(b)(3)-1: Child Victims' and Child Witnesses' Rights Act, 18 U.S.C. § 3509
(49) In Exemption category (b)(3)-1, the FBI protected information pertaining to child
victims and witnesses. The privacy protection measures enacted in 1990, within the Child
Victims' and Child Witnesses' Rights Act, 18 U.S.C. § 3509, were created to protect minor
children involved in criminal proceedings. This statute was enacted well before the Open FOIA
Act of 2009. Moreover, it refers to particular types of matters that must be withheld from public
disclosure. Specifically, 18 U.S.C. $ 3509(d) protects from disclosure certain records containing
identifying information pertaining to children involved in criminal proceedings. A child is
defined in 18 U.S.C. $ 3509(a)(2) as "a person who is under the age of 18, who is or is alleged to
be (A) a victim of a crime of physical abuse, sexual abuse, or exploitation; or (B) a witness to a
crime committed against another person." Accordingly, the FBI asserted Exemption 3, at times
in conjunction with Exemptions 6, 7(C) and 7(D), to protect names, images, and identifying
information of minor children victims and witnesses within the child prostitution investigation of
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=== Page 18 ===
Author: CGM
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Jeffrey Epstein.
(b)(3)-2: Federal Grand Jury Information - Federal Rule of Criminal Procedure (6)(e)
(50) In Exemption category (b)(3)-2, the FBI protected Federal Grand Jury
information pursuant to Federal Rule of Criminal Procedure 6(e). As relevant to 5 U.S.C. $
552(b)(3)(B), Rule 6(e) is a statute¹⁴ enacted before the date of enactment of the OPEN FOIA
Act of 2009. 15 It is well-established that Rule 6(e) embodies a broad, sweeping policy of
preserving the secrecy of grand jury material regardless of the substance in which the material is
contained. Records responsive to Plaintiffs' request details matters occurring before one or more
federal grand juries empaneled in relation to the investigations at issue. Specifically, the
investigative files contain information about the names of recipients of federal grand jury
subpoenas; information that identifies specific records subpoenaed by a federal grand jury; and
copies of specific records provided pursuant to federal grand jury subpoenas. Wherever the FBI
protected this information, it found a clear nexus to federal grand jury proceedings on the face of
the responsive documents. Any disclosure of this information would clearly violate the secrecy
of the grand jury proceedings and could reveal the inner workings of a federal grand jury. Thus,
the FBI properly withheld this information pursuant to Exemption 3, in conjunction with Rule
14 As prescribed by 18 U.S.C. § 3771 (subsequently repealed by Pub.L. 100-702, Title IV, $
404(a)(1) (Nov. 19, 1988) and replaced by 28 U.S.C. § 2074), proposed rules become effective
ninety days after the Chief Justice reports them to Congress. By order of April 26, 1976, the
Supreme Court adopted amendments to the Federal Rules of Criminal Procedure which included
Rule 6(e) and reported the amendments to Congress. Congress voted to delay the effective date
of several of the proposed rules, to include Rule 6(e), "until August 1, 1977, or until and to the
extent approved by Act of Congress, whichever is earlier." Pub. L. No. 94-349 $ 1, 90 Stat. 822
(1976). Subsequently, Congress, by statute, enacted a modified version of Rule 6(e). See Pub.L.
No. 95-78, § 2(a), 91 Stat. 319 (1977), FED. R. CRIM. P. 6(e).
15 The OPEN FOIA Act of 2009 was enacted October 28, 2009. See Pub.L. 111-83, 123 Stat.
2142, 2184.
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=== Page 19 ===
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6(e).
(b)(3)-3: Juvenile Justice and Delinquency Act - 18 U.S.C. § 5038
(51) The Juvenile Justice and Delinquency Act, 18 U.S.C. $ 5038, protects from
disclosure all information and records relating to any juvenile delinquency proceeding, unless the
release is necessary to meet certain circumstances described within the statute. This statute was
enacted before the Open FOIA Act of 2009, but meets the standards of 5 U.S.C. 552 § (A)(ii) as
it establishes particular criteria for withholding and describes particular types of matters to be
withheld. The records at issue here contain arrest information and criminal history of third party
juveniles. Plaintiffs' request does not meet the specific circumstances set forth in the statute for
disclosure; therefore, the records are properly withheld pursuant to Exemption category (b)(3)-3.
Additionally, the FBI also asserted Exemptions 6 and 7(C) over all information that falls within
this category.
EXEMPTION 5 - PRIVILEGED INFORMATION
(52) FOIA Exemption 5 has been construed to exempt documents or information
normally privileged in the civil discovery context and incorporates the deliberative process
privilege and attorney work product doctrine. In order to apply Exemption 5, agencies must first
satisfy the threshold requirement - i.e., show that the information protected consists of "inter-
agency or intra-agency" information. Once the threshold is satisfied, agencies must satisfy the
elements of the pertinent privilege. (b)(5)-1: Deliberative Process Privilege
(53) In Exemption Category (b)(5)-1, the FBI protected privileged, deliberative
materials. The deliberative process privilege protects predecisional, deliberative
communications that are part of a process by which agency decisions are made. It therefore
encompasses opinions, advice, evaluations, deliberations, analyses, proposals, or
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=== Page 20 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
recommendations that form part of an agency decision-making process. The privilege also
protects records and information that if disclosed, would reveal the agency's collection of
multitudinous facts, and the selection, sorting, evaluation, and analysis of those facts relied upon
as part of the decision-making process. Agencies must show that the withheld information was
both predecisional - i.e., antecedent to a final agency decision - and deliberative - i.e., part of
the process in which the agency engaged in an effort to reach a final decision (whether or not any
final decision was ever reached).
(54) Exemption 5, when asserted in conjunction with the deliberative process
privilege, is predicated on the recognition that release of this privileged information would
inhibit the government's development of policy and stifle its decision-making process.
Furthermore, exempting such documents from disclosure also protects against public confusion
that might result from preliminary disclosure of opinions and information that do not, in fact,
reflect the final views or policies of the FBI. The exemption and privilege together protect not
only documents but also the integrity of the deliberative process itself where exposure of the
process would result in harm. The FBI invokes Exemption 5 and the deliberative process
privilege because FBI employees would hesitate to offer their candid and conscientious opinions
to superiors or coworkers if they knew that their opinions of the moment might be made a matter
of public record at some future date, and because such self-censorship would, in turn, degrade
the quality of agency decisions by depriving the decision-makers of fully-explored options
developed from robust debate.
(55) As described in more detail below, the FBI relied on Exemption 5 and the
deliberative process privilege to protect internal deliberative communications and draft
documents. These materials reflect deliberations integral to reaching final agency decisions or
20
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=== Page 21 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
were key to a decision-making process aimed at developing policy/best agency decisions. The
communications and drafts are deliberative and pre-decisional. Additionally, as contemplated by
the FOIA Improvement Act of 2016, all of the protected material was created less than 25 years
before the submission of Plaintiff's request.
Deliberative Communications
(56) The FBI asserted Exemption 5 to withhold deliberative communications. These
communications contain or consist of material related to deliberations by DOJ employees who
are making proposals and/or working to come to a consensus on final agency decisions.
Specifically, this material includes FBI and the United States Attorney ("AUSA") discussions on
the handling of Jeffrey Epstein's asset forfeiture and his pending indictment. The material
protected is pre-decisional in that it discusses proposed actions and considerations and does not
reflect final agency decisions. The harm in release here would be a chilling effect on agency
employees' willingness to share raw, unrefined ideas and candid feedback should they know it
could become subject to public disclosure. Release could set a dangerous precedent as the FBI
would be seen as unwilling to shield its employees' deliberations from public scrutiny and could
result in hesitancy to participate fully in such deliberations by FBI employees during future
deliberations. Additionally, release of this material would create public confusion as this
material predates final agency decisions. It could potentially cast doubt on the accuracy of
actual, final agency decisions/policies or cause public misunderstanding as to what are the actual
FBI policies/decisions.
Draft Materials
(57) The FBI also asserted Exemption 5 to withhold draft documents that are clearly
marked as strictly confidential, draft for discussions only. These draft documents are legal
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=== Page 22 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
documents created during the prosecution of Jeffrey Epstein and are inherently part of the
deliberative process. They predate final agency decisions and reflect the give-and-take of
deliberations, through the editing process, which leads to final, refined products. In the instances
where the FBI withheld draft material pursuant to Exemption 5, the FBI found the draft material
was shared between FBI and DOJ, was pre-decisional, was deliberative (the material was shared
to solicit feedback/edits), and release could potentially harm agency deliberations. The harm
here would be a chilling effect on agency employees' willingness to share such drafts if they
knew their unrefined ideas would be subject to public disclosure. Furthermore, there would be a
risk of public confusion in that these drafts do not reflect final agency decisions.
(58)
For the reasons discussed above, the FBI properly protected two types of
deliberative materials described under Exemption 5, in conjunction with the deliberative process
privilege. The FBI endeavored to segregate non-deliberative facts, whenever possible, and only
withheld such material when it found it was inextricably intertwined with agency deliberations.
(b)(5)-2: Attorney Work Product Privilege
(59) In Exemption category (b)(5)-2, the FBI protected information subject to the
attorney work product doctrine. The attorney work product privilege protects such tangible and
intangible items as interviews, memoranda, correspondence, mental impressions, and personal
beliefs prepared or developed by an attorney, or at the direction of an attorney, in reasonable
anticipation of litigation. The privilege is predicated on the recognition that proper preparation
of a case depends on an attorney's ability to assemble information, sort relevant from irrelevant
facts, and prepare his/her legal theories and strategies without intrusive or needless scrutiny.
(60) The FBI relied on the attorney work product privilege to protect inter-agency
materials created at the direction of an attorney in reasonable anticipation of litigation.
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=== Page 23 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
Specifically, the FBI protected information regarding legal strategy and evidence gathering
conducted by the FBI SAs assigned to the criminal investigation into activities of Jeffrey
Epstein, at the direction of an AUSA, in March 2007. This guidance and documents compiled,
provides details of the AUSA's prosecutorial strategy and the inner workings of how the AUSA
planned to build the legal framework to support an indictment of Jeffrey Epstein. This
information satisfies Exemption 5's threshold of being inter-agency because these records were
exchanged within Department of Justice (i.e., between the FBI and U.S. Attorney's Office).
Furthermore, these records are quintessential attorney work products and readily satisfy the
elements of the attorney work product privilege because they were created for an attorney
working to build a legal case to seek indictment and prosecution of a child prostitution criminal
case. As described supra, release of this type of information would interfere with the
government attorney's ability to properly prepare their legal theories and strategies and hinder
them in providing the best possible representation of their clients [the government]. Finally,
because the attorney work product privilege protects both factual and deliberative material,
segregation is not required. Accordingly, the FBI properly withheld this information pursuant to
Exemption 5.
EXEMPTION 7 THRESHOLD
(61) Before an agency can invoke any of the harms enumerated in Exemption (b)(7), it
must first demonstrate that the records or information at issue were compiled for law
enforcement purposes. Pursuant to 28 U.S.C. §§ 533, 534, and Executive Order 12,333 as
implemented by the Attorney General's Guidelines for Domestic FBI Operations (AGG-DOM)
and 28 CFR $ 0.85, the FBI is the primary investigative agency of the federal government with
authority and responsibility to investigate all violations of federal law not exclusively assigned
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=== Page 24 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
to another agency, to conduct investigations and activities to protect the United States and its
people from terrorism and threats to national security, and further the foreign intelligence
objectives of the United States. Under this investigative authority, the responsive records herein
were compiled in furtherance of the FBI's investigation of criminal child prostitution involving
Jeffrey Epstein. As these records were compiled as part of the FBI's investigation of potential
federal crimes, they were compiled for law enforcement purposes.
EXEMPTION 7(A)
PENDING LAW ENFORCEMENT PROCEEDINGS
(62) 5 U.S.C. § 552 (b)(7)(A) exempts from disclosure:
records or information compiled for law enforcement purposes, but
only to the extent that the production of such law enforcement
records or information could reasonably be expected to interfere
with enforcement proceedings.
(63) Application of this exemption requires: the existence of law enforcement records;
a pending or prospective law enforcement proceeding; and a determination that release of the
information could reasonably be expected to interfere with the enforcement proceeding. Often,
the FBI asserts Exemption 7(A) categorically to withhold a variety of different documents in an
investigative file, which the FBI then groups into functional categories and describes in greater
detail. In this case, however, the FBI asserted Exemption 7(A) to protect the ongoing
prosecution of Jeffrey Epstein and then later, of his potential co-conspirators. The release of this
information would reveal unknown information concerning pending enforcement procedures.
The FBI determined release of any of this material would provide criminals with information
about the government's investigation/enforcement strategies in ongoing matters, allow them to
predict and potentially thwart these strategies, and/or allow them to discover/tamper with
witnesses and/or destroy evidence. As such, revealing this information could reasonably be
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=== Page 25 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
expected to interfere with pending enforcement proceedings. Thus, the FBI has applied
Exemption 7(A) to protect this information. Additional information regarding the nature of the
on-going criminal enforcement proceedings, and the harms to those proceedings that could result
from the release of these categories of records, is provided in the declaration of AUSA
PROCESSING OF RECORDS AFTER ARREST OF MR. EPSTEIN ON JULY 6, 2019
Types of Documents Categorically Denied Pursuant to FOIA Exemption 7(A)
(64)
Providing a document-by-document description or listing of the records
responsive to Plaintiff's request falling in the categorically denied records would undermine the
very interests that the FBI seeks to protect under Exemption (b)(7)(A), in addition to the other
exemptions identified below. In order to protect these interests, the FBI has described the types
of responsive records from the pending investigative files, which are being withheld in full
pursuant to FOIA Exemption (b)(7)(A). The pending investigative files contain the following
types of documents:
(a) FD-105716 - Electronic Communication ("EC"): FD-1057s and ECs replaced the
traditional FBI correspondence (i.e., Memoranda and Letters) as the primary vehicle
of correspondence within the FBI. The purpose of an EC is to communicate within
the FBI in a consistent format that can be uploaded by the originating Division or
office, transmitted, and downloaded by recipient Divisions or offices within the FBI's
internal computer network. These forms are often utilized to record and disseminate
intelligence/investigative information and for general investigation administration
purposes.
16 The designation "FD-" is attached to forms created and utilized internally by the FBI.
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=== Page 26 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(b) Interview Forms (FD-302): FD-302s are internal FBI forms in which evidence is
often documented, usually as a result of FBI interviews. Such evidence and/or
interview information may later be used as testimony or evidence in court
proceedings/trials. Additionally, these evidence/interview forms are often
incorporated in other FBI documents that may be used to disseminate
intelligence/investigativ information and can be utilized to set leads in furtherance of
the FBI's investigative efforts.
(c) Handwritten Interview Notes: These are the original handwritten notes of FBI
personnel who conducted interviews in the course of FBI investigations. These notes
are almost always transposed into FD-302s and are utilized by the FBI in the same
manner.
(d) State and Local Law Enforcement Documents: This category consists of documents
provided, to the FBI by state and local law enforcement agencies. These documents
can be used as evidence in court proceedings, are often incorporated in other FBI
documents that may be used to disseminate intelligence/investigative information,
and can be utilized to set leads in furtherance of the FBI's investigative efforts.
(e) Documents Implementing Sensitive Investigative Techniques: These documents were
utilized to implement a specific, sensitive, investigative technique. Describing these
documents further would reveal this technique or sensitive data concerning this
technique.
(f) Federal Grand Jury Subpoenas/Subpoenaed Information: These documents consist of
Federal Grand Jury Subpoenas and the documents collected as a result of these
subpoenas. This information can be used as evidence in Grand Jury proceedings or
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=== Page 27 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
other court proceedings. This information can also be incorporated in FBI documents
that may be used to disseminate intelligence/investigativ information, and can be
utilized to set leads in furtherance of the FBI's investigative efforts.
(g) FD-340, 1A Envelopes: These envelopes are used to organize and store documents
that need to be stored separately from the FBI file to which they are attached, due to
their size. They usually contain handwritten notes of interviews, photographs, and
other various evidentiary documents.
(h) Other Investigative Documents: The FBI uses various types of forms throughout a
criminal investigation that do not fit into an official government format. Documents
included in this category may include, but is not limited to, storage envelopes, bulky
exhibit cover sheets, transmittal forms (e.g., facsimile cover sheets), letters, and
routing slips. Additionally, this category consists of various types of documents
reflecting information and evidence gathered during an FBI investigation, the sources
from/by which such information and evidence was gathered, methods used to obtain
the information and evidence, and methods used to analyze the information and
evidence. To describe these investigative documents in this category any more
specifically would reveal the scope of the FBI's investigations, as well as the sources
and methods being utilized by the FBI.
(i) Internet Printouts: These documents consist of information that was located and
printed from public websites. Disclosure of information gathered from a public
source may itself reveal the direction or focus of an investigation by demonstrating
what an investigator found relevant.
Functional Categories of Information
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=== Page 28 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(65) The FBI has reviewed and categorized the types of exempt records into three
categories - Evidentiary/Investigative Materials, Administrative Materials and Public
Source/Non-Investigative Harm Materials. The categories will be discussed in more detail
below.
(66) A record can fall into one or more functional categories as described in the below
paragraphs. For example, a record, such as an FBI Investigative Report, may serve several
purposes and may contain multiple categories of information, such as witness statements,
administrative directions, and/or evidentiary materials. Therefore, the information in each record
could be included in multiple categories.
Category 1: Evidentiary/Investigative Materials
(67) This category includes copies of records or evidence, analyses of evidence, and
derivative communications discussing or incorporating evidence. A derivative communication
describes, verbatim or in summary, the contents of the original record, how it was obtained, and
how it relates to the investigation. Other derivative communications report this information to
other FBI field offices, other law enforcement agencies, or other Federal agencies, either to
advise them about the progress of the investigation, or to elicit their assistance in handling
investigative leads. The following subparagraphs describe the types of evidentiary materials in
the responsive records and the anticipated harm that could reasonably result from the release of
the materials.
(68) Confidential Witness Statements: Confidential witness statements are one of the
principal tools used in proving the facts which form the basis for a prosecution. These
statements contain information obtained from confidential witnesses who have knowledge of the
criminal activities that resulted in the investigation. If the FBI were to release this information,
28
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=== Page 29 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
the witnesses that have chosen to cooperate with law enforcement could be subjected to
retaliation, intimidation, or physical or mental harm. This could have a chilling effect on the
future prosecution of this case inasmuch as potential witnesses might fear exposure and reprisals
from the subjects of this investigation. Implicit in conducting interviews in an investigation of
this nature is the notion that an individual's identity and the information provided by them will
be afforded confidentiality. The FBI goes to great lengths to protect and maintain an individual's
confidentiality since it is an integral part of a successful investigation and prosecution. The
release of witness statements would disrupt and harm potential investigative and/or prosecutorial
actions.
(69) Exchange of Information between FBI and Local Law Enforcement Agencies:
Release of information exchanged between the FBI and its local law enforcement partners would
disclose evidence, investigative information, and criminal intelligence developed by various
agencies that have cooperated with-and provided information and records to-the FBI in this
ongoing investigation. Release of information would identify the investigative interest of
particular individuals; identify and tip off individuals who are of interest to law enforcement; and
provide suspects or targets the opportunity to destroy evidence and/or alter their behavior to
avoid detection.
Category 2: Administrative Materials
(70) Materials falling within this category include items such as case captions,
identities of FBI field offices, dates of investigations, and detailed instructions designed to
ensure that investigative procedures are conducted within the appropriate FBI and DOJ
guidelines. The following subparagraphs describe the types of administrative materials
contained in the files and the anticipated harms that could reasonably result from the disclosure
29
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=== Page 30 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
of such materials in the midst of this ongoing investigation, and prior to any prospective
prosecutions. In many instances, administrative information is contained at the beginning or end
of correspondence or documents that fall within other categories of documents; therefore, to
release details on this category of information would also reveal the investigative interests of the
FBI and could enable suspects to discern a "road map" of the investigation.
(71) Reporting Communications: These communications permit an agency to monitor
the progress of the investigation and to facilitate its conduct. These communications have the
potential to reveal or confirm the cooperation of other local or state government agencies in this
investigation. These communications are replete with detailed information about the FBI's
investigative activities as well as detailed information about potential witnesses/confidential
sources for interview. Additionally, they contain background information about third-party
individuals, the origins of pertinent information connecting them to the investigation, and their
connections to subjects and their relationship with the pending investigation. The release of this
information would reveal the nature and scope of the ongoing investigation by revealing: the
investigative steps taken to obtain witness and source interviews; techniques and investigative
methods used to compile and/or solicit information from various sources; and any potential or
perceived challenges in the investigations.
(72) Miscellaneous Administrative Documents: These materials include items such as
transmittal forms and standardized forms used for a variety of purposes. These types of
materials have been used throughout this investigation for many routine purposes; however, the
manner in which they have been used and organized in the files also reveals information of
investigative value. The disclosure of this information could undermine this pending and
ongoing investigation as well as pending and prospective prosecutions.
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=== Page 31 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
Category 3: Public Source/Non-Investigative Harm Materials
(73) The FBI released 46 pages to Plaintiffs of public source material not posing an
investigative harm from within the investigative files. Prior to the shift in processing to the
categorical review, the FBI released an additional 135 pages in full to Plaintiffs. The FBI
determined that this information could be released without harm to the ongoing investigations, as
the information is already known to the public and is not reasonably expected to interfere with
pending criminal law enforcement proceedings or prosecutions. Thus, the disclosure of this
information would not result in any of the various harms under Exemption 7(A) as described
herein.
(74) During the course of an FBI investigation, including this one, relevant and
pertinent articles in newspapers, magazines or other periodicals are placed by FBI employees
into the investigative file. These materials contain information obtained from public sources
such as newspapers, on-line material, court transcripts, criminal affidavits, and other court
filings. FBI employees place these public source materials into the file for background and
review purposes. In this case, the public source material released to Plaintiffs consisted of news
articles and various public court documents from Epstein's criminal case. Because the FBI had
determined that the release of these specific public source documents would not harm or
otherwise jeopardize the ongoing criminal investigation, the FBI did not withhold these
documents from the Plaintiffs.
EXEMPTIONS 6 AND 7(C)
CLEARLY UNWARRANTED INVASION OF PERSONAL PRIVACY
AND UNWARRANTED INVASION OF PERSONAL PRIVACY
(75) Exemption 6 exempts from disclosure "personnel and medical files and similar
files the disclosure of which would constitute a clearly unwarranted invasion of personal
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=== Page 32 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
privacy." 5 U.S.C. $ 552(b)(6). All information that applies to a particular person falls within
the scope of Exemption 6.
(76) Exemption 7(C) similarly exempts from disclosure "records or information
compiled for law enforcement purposes [when disclosure] could reasonably be expected to
constitute an unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(7)(C).¹⁷
(77) When withholding information pursuant to these two exemptions, the FBI is
required to balance the privacy interests of the individuals mentioned in these records against any
public interest in disclosure. In asserting these exemptions, each piece of information was
scrutinized to determine the nature and strength of the privacy interest of every individual whose
name and/or identifying information appears in the documents at issue. When withholding the
information, the individual's privacy interest was balanced against the public's interest in
disclosure. For purposes of these exemptions, a public interest exists only when information
about an individual, their name, or other factors that could potentially identify the individual¹⁸
would shed light on the FBI's performance of its mission to protect and defend the United States
against terrorist and foreign intelligence threats, to uphold and enforce the criminal laws of the
United States, and to provide leadership and criminal justice services to federal, state, municipal,
17 The practice of the FBI is to assert Exemption 6 in conjunction with Exemption 7(C).
Although the balancing test for Exemption 6 uses a "would constitute a clearly unwarranted
invasion of personal privacy" standard and the test for Exemption 7(C) uses the lower standard
of "could reasonably be expected to constitute an unwarranted invasion of personal privacy," the
analysis and balancing required by both exemptions is sufficiently similar to warrant a
consolidated discussion. The privacy interests are balanced against the public's interest in
disclosure under both exemptions.
18 As used herein, identifying information includes the following: dates of birth, places of birth,
residences, telephone numbers, social security numbers, singular professional titles, statements,
unique locations, and/or other information that is identifiable to an individual.
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=== Page 33 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
and international agencies and partners. In each instance wherein information was withheld
pursuant to Exemptions 6 and 7(C), the FBI determined that the individuals' privacy interests
outweighed any public interest in disclosure.
(78) Furthermore, since privacy concerns are typically obviated once an individual is
deceased,19 the FBI takes several steps, during FOIA processing, to ascertain the current
life/death status of the individuals whose names are withheld. The FBI uses the birth date and/or
the date of the investigation to determine whether an individual is living or deceased, to the
extent either or both of these pieces of information are discernable from the file. The date of
birth is used to apply the judicially-recognized "100-year rule," i.e., if the individual was born
more than 100 years ago, the FBI presumes that he or she is dead and the name and/or
identifying information is released. The FBI also uses institutional knowledge gained from prior
FOIA requests or internal records. By using institutional knowledge, the FBI can identify with
sufficient certainty the life/death status of certain individuals. If the FBI is unable to determine
the life/death status of an individual through the use of these methods, the name and identifying
information of the individual is withheld pursuant to Exemptions 6 and 7(C), when it finds
disclosure would constitute an unwarranted invasion of those individuals' privacy should they
still be living and no public interest would be served in releasing the names. It is also the FBI's
policy to release all names of high-ranking FBI officials in policy-making positions, as well as
individuals in public positions, as they do not have privacy rights while acting in their official
capacity. This policy is applied to the individual's position at the time of the creation of the
document, and not the present.
19 In some circumstances, surviving relatives of a deceased individual retain privacy interests in
their information, even after the individual's death. See generally National Archives V. Favish,
124 S. Ct. 1570 (2004).
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=== Page 34 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(b)(6)-1 and (b)(7)(C)-1: Names and Identifying Information of
Third Parties of Investigative Interest
(79) Within Exemption category (b)(6)-1 and (b)(7)(C)-1, the FBI protected the names
and identifying information of third parties who were of investigative interest to the FBI. Being
identified as a subject of FBI investigative interest carries a strong negative connotation and a
stigma, whether or not these individuals ever committed criminal acts. Release of the identities
of these individuals to the public could subject them to harassment or embarrassment, as well as
undue public attention. Furthermore, it could result in professional and social repercussions, due
to resulting negative stigmas. Accordingly, the FBI determined these individuals maintain
substantial privacy interests in not having their identities disclosed. In contrast, disclosing
personal information about these individuals would not significantly increase the public's
understanding of the FBI's performance of its mission and so the FBI concluded that there was
no public interest here sufficient to override these individuals' substantial privacy interests. For
these reasons, the FBI properly withheld this information pursuant to Exemptions 6 and 7(C).
(b)(6)-2 and (b)(7)(C)-2: Names and Identifying Information of
FBI Special Agents and Victim Specialists
(80) Within Exemption category (b)(6)-2 and (b)(7)(C)-2, the FBI protected the names
and identifying information of FBI Special Agents ("SAs") and Victim Specialists. These FBI
personnel were responsible for conducting, supervising, and/or maintaining the
investigation/investigative activities related to the child prostitution investigation of Jeffrey
Epstein, reflected in the documents responsive to Plaintiffs' request. These responsibilities
included, but are not limited to, the following: coordinating/completing tasks in support of the
FBI's investigative and administrative functions, compiling information, and/or reporting on the
status of the investigation.
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=== Page 35 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(81) Assignments of SAs to any particular investigation are not by choice. Publicity,
adverse or otherwise, arising from a particular investigation, may seriously prejudice their
effectiveness in conducting other investigations or performing their day-to-day work. The
privacy consideration is also applied to protect FBI SAs, as individuals, from unnecessary,
unofficial questioning as to the conduct of this or other investigations/investigative activities,
whether or not they are currently employed by the FBI. FBI SAs conduct official inquiries into
various criminal and national security violation cases. The publicity associated with the release
of an SA's identity in connection with a particular investigation could trigger hostility toward a
particular SA. During the course of an investigation, an SA may engage with all strata of
society, conducting searches and making arrests, both of which result in reasonable but
nonetheless serious disturbances to people and their lives. Persons targeted by such
investigations/investigative activities, and/or those sympathetic to those targeted, could seek to
inflict violence on an SA based on their participation in an investigation. This is because an
individual targeted by such law enforcement actions may carry a grudge against those involved
with the investigation, which may last for years. These individuals may seek revenge on SAs
and other federal employees involved in a particular investigation. There is no public interest
served by disclosing the identities of the SAs because their identities would not, themselves,
significantly increase the public's understanding of the FBI's operations and activities.
(82) The role of a Victim Specialist is to aid with those who suffered through physical,
emotional, or financial harm as a result of a crime. A standard service provided by a Victim
Specialist, specifically within these documents is to accompany SAs to interviews and provide as
a critical link between the SAs and the victims for the Victim Assistance Program ("VAP").
VAP helps the victims cope and recover from the harm they have endured while allowing the
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SAs to continue forward with their investigations. Protection of the Victim Specialists' identities
is not only imperative for their safety, but also the victims' safety and allows the victims to
confide to the FBI personnel involved in the investigation. Thus, disclosure of this information
would constitute a clearly unwarranted invasion of their personal privacy; and the FBI properly
withheld the names and identifying information of FBI SAs and Victim Specialists pursuant to
Exemptions 6 and 7(C).
(b)(6)-3 and (b)(7)(C)-3: Names and Identifying Information Regarding
Third Party Victims
(83) In Exemption category (b)(6)-3 and (b)(7)(C)-3, the FBI protected the names and
identifying information of third-party victims. Releasing these individuals' identities in the
context of these investigative records would cause embarrassment, as well as unsolicited and
unnecessary attention to be focused on these individuals. Such a release could force them to
relive emotionally trying events, causing further invasion of their privacy, in excess of the harms
they have already been forced to endure. Thus, these victims maintain strong privacy interests in
the protection of such personal information. Furthermore, there is no legitimate public interest to
be served by releasing the identities of these victims because their identities, themselves, would
not shed light on the operations and activities of the FBI. The FBI determined disclosure of this
information would constitute a clearly unwarranted invasion of these individuals' personal
privacy, and consequently withheld this information pursuant to FOIA Exemptions 6 and 7(C).
Accordingly, the FBI asserted this Exemption category, at times in conjunction with Exemptions
3 and 7(D).
(b)(6)-4 and (b)(7)(C)-4: Names and Identifying Information of
Local Law Enforcement Personnel
(84) In Exemption category (b)(6)-4 and (b)(7)(C)-4 the FBI protected the names and
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Author: CGM
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identifying information of local law enforcement employees. These employees were acting in
their official capacities and aided the FBI in the law enforcement investigative activities reflected
in the records responsive to Plaintiffs' request. The rationale for protecting the identities of FBI
SAs discussed in " 81-83, supra, applies equally to the names and identifying information of
these local law enforcement employees. Release of the identities of these law enforcement
employees could subject them as individuals to unnecessary and unwelcome harassment that
would invade their privacy and could cause them to be targeted for reprisal. In contrast,
disclosure of this information would serve no public interest because it would not shed light on
the operations and activities of the FBI. Accordingly, the FBI properly withheld this information
pursuant to Exemptions 6 and 7(C).
(b)(6)-5 and (b)(7)(C)-5: Names and Identifying Information of
Third Parties Merely Mentioned
(85) In Exemption category (b)(6)-5 and (b)(7)(C)-5, the FBI protected the names and
identifying information of third parties who were merely mentioned in the investigative records
responsive to Plaintiffs' request. The FBI has information about these third parties in its files
because these individuals were tangentially mentioned in conjunction with FBI investigative
efforts. These individuals were not of investigative interest to the FBI. These third parties
maintain substantial and legitimate privacy interests in not having this information disclosed and
thus, being connected with an FBI law enforcement matters. Considering the FBI is an
investigative and intelligence agency, disclosure of these third parties' names and/or identifying
information in connection with an FBI record carries an extremely negative connotation.
Disclosure of their identities would subject these individuals to possible harassment or criticism
and focus derogatory inferences and suspicion on them. The FBI then considered whether there
was any public interest that would override these privacy interests, and concluded that disclosing
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Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
information about individuals who were merely mentioned in an FBI investigative file would not
significantly increase the public's understanding of the operations and activities of the FBI.
Accordingly, the FBI properly protected these individuals' privacy interests pursuant to FOIA
Exemptions 6 and 7(C).
(b)(6)-6 and (b)(7)(C)-6: Names and Identifying Information of
Non-FBI Federal Government Personnel
(86) In Exemption category (b)(6)-6 and (b)(7)(C)-6, the FBI protected the names and
identifying information of personnel from non-FBI, federal government agencies who provided
information to or otherwise assisted the FBI in its investigation of Jeffrey Epstein. The rationale
for protecting the identities of other government employees is the same as the rationale for
protecting the identities of FBI employees. See 11 81-83, supra. Publicity, adverse or otherwise,
concerning the assistance of these other agency employees in an FBI investigation would
seriously impair their effectiveness in assisting or participating in future FBI investigations. The
privacy consideration also protects these individuals from unnecessary, unofficial questioning as
to the FBI investigation. It is possible for a person targeted by law enforcement action to carry a
grudge which may last for years, and to seek revenge on the personnel involved in the
investigation at issue in these FBI records. The publicity associated with the release of their
names and/or identifying information in connection with this investigation could trigger hostility
towards them by such persons. Therefore, these employees maintain substantial privacy interests
in not having their identities disclosed in this context. In contrast, there is no public interest to be
served by the disclosure of these employees' names and/or identifying information because their
identities, by themselves, would not demonstrate how the FBI performed its statutory mission
and thus, would not significantly increase the public's understanding of the FBI's operations and
activities. Accordingly, the FBI properly protected these employees' privacy interests pursuant
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=== Page 39 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
to FOIA Exemptions 6 and 7(C).
(b)(6)-7 and (b)(7)(C)-7: Names and Identifying Information of
Local Government Personnel (Non-Law Enforcement)
(87) In Exemption category (b)(6)-7 and (b)(7)(C)-7 the FBI protected the names and
identifying information of local government personnel employees. The rationale for protecting
the identities of local law enforcement personnel discussed in 85, supra, applies equally to the
names and identifying information of these local government employees. Release of the
identities of these local government employees could subject them as individuals to unnecessary
and unwelcome harassment that would invade their privacy and could cause them to be targeted
for reprisal. In contrast, disclosure of this information would serve no public interest because it
would not shed light on the operations and activities of the FBI. Accordingly, the FBI properly
withheld this information pursuant to Exemptions 6 and 7(C).
(b)(6)-8 and (b)(7)(C)-8: Names and Identifying Information of
Third Parties who Provided Information
(88) In Exemption category (b)(6)-8 and (b)(7)(C)-8, the FBI protected the names and
identifying information of individuals who were interviewed, and/or provided information by
other means, to the FBI during the course of its investigation of Jeffrey Epstein.
(89) The FBI has found information provided by individuals based on their personal
knowledge is one of the most productive investigative tools for law enforcement agencies. The
largest obstacle to successfully obtaining such information critical to FBI investigations, through
an interview or otherwise, is fear by the individuals providing the information their identities will
be exposed. Such exposure, in conjunction with their cooperation with law enforcement, could
lead to harassment, intimidation by investigative subjects, legal or economic detriment, possible
physical harm, or even death. In order to surmount their fear of reprisal, and the resulting
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Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
tendency to withhold information, persons who provide such information to the FBI must be
assured their names and personally-identifying information will be held in the strictest
confidence. Thus, the FBI has determined these individuals maintain substantial privacy
interests in not having their identities disclosed. In contrast, the FBI could identify no public
interest in the disclosure of this information because disclosure of these third parties' names and
identifying information would not shed light on or significantly increase the public's
understanding of the operations and activities of the FBI. Furthermore, the continued access by
the FBI to persons willing to honestly relate pertinent facts bearing upon a particular
investigation far outweighs any benefit the public might derive from disclosure of the names of
those who cooperated with the FBI. Accordingly, the FBI properly protected these individuals'
privacy interests pursuant to Exemptions 6 and 7(C). The FBI is also relying on Exemption
7(D) to protect this information in many instances.
EXEMPTION 7(D) - CONFIDENTIAL SOURCE INFORMATION
(90) Exemption 7(D) protects "records or information compiled for law enforcement
purposes" when disclosure:
could reasonably be expected to disclose the identity of a
confidential source, including a State, local or foreign agency or
authority or any private institution which furnished information on
a confidential basis, and, in the case of a record or information
compiled by a criminal law enforcement agency conducting a lawful
national security intelligence investigation, information furnished
by a confidential source.
5 U.S.C. $ 552(b)(7)(D).
(91) Numerous confidential sources report to the FBI on a regular basis; they provide
information under express assurances of confidentiality and are "informants" within the common
meaning of the term. Others are interviewed and/or provide information under implied
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Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
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assurances of confidentiality (i.e., under circumstances from which assurances of confidentiality
may be inferred). In either situation, these sources are considered to be confidential because they
furnish information only with the understanding that their identities and the information they
provided will not be divulged outside the FBI. Information provided by these sources is singular
in nature, such that it is often distinct and traceable to a specific individual and if released, could
reveal their identities. The FBI has learned through experience that sources assisting,
cooperating with, and providing information to the FBI must be free to do so without fear of
reprisal. The FBI has also learned that sources must be free to furnish information to the FBI
with complete candor and without the understandable tendency to hedge or withhold information
because of fear that their cooperation with the FBI will later be made public. Sources providing
information to the FBI should be secure in the knowledge that their assistance and their identities
will be held in confidence.
(92) The release of a source's identity would forever eliminate that source as a future
means of obtaining information. In addition, when the identity of one source is revealed, that
revelation has a chilling effect on the activities and cooperation of other sources. Such a result
undermines one of the FBI's most important means of collecting information and could thereby
severely hamper law enforcement efforts to detect and apprehend individuals engaged in the
violation of federal criminal laws.
(b)(7)(D)-1: Names, Identifying Information of, and Information Provided by Individuals under
Implied Assurances of Confidentiality
(93) In Exemption category (b)(7)(D)-1, the FBI protected the names, identifying
information of, and information provided by third parties under circumstances in which
confidentiality can be inferred. These third parties provided information concerning the
activities of subjects who were of investigative interest to the FBI. Considering 1) the singularity
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Author: CGM
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Deliberative Process/Attorney-Client/Attorney Work Product Privileged
of the information provided and the likelihood these individuals could be identified through
release of this information by those familiar with the events described; 2) the proximity of these
sources to the investigative subjects and events they described; 3) and the nature of the criminal
acts they described, the FBI inferred these individuals provided this information to the FBI only
because they believed their cooperation with the FBI, and the information they provided, would
remain confidential.
(94) The FBI protected the identifying information of, and information provided by,
individuals who conveyed critical information regarding criminal acts. These individuals were
in unique positions allowing them ready access to and/or knowledge about investigative targets
and others involved in child prostitution or trafficking of a minor. Such access exposed them to
potentially significant harms should their association and cooperation with the FBI be publicly
disclosed. One reason they risked harm when cooperating is they were within the orbit of
suspected criminals, and such criminals (in the FBI's experience) typically seek to deter
informants' cooperation with law enforcement through reprisal. Such reprisal can take many
forms, to include defamation of the source's character among their peers/family; economic
reprisal (deprivation of employment/business opportunities); violent threats aimed at instilling
fear and doubt; or even violence itself. Even amidst these potential harms, these third-party
sources provided specific, detailed information that is singular in nature - i.e., only a few
individuals would be privy to such information. Thus, the FBI determined disclosure of the
identities of these sources and the information they provided could subject these third parties, as
well as their families, to retaliation or backlash, should their information be disclosed.
(95) Considering the circumstances described above, it is reasonable to infer these
third parties cooperated with the FBI only because they expected their identities and the
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=== Page 43 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
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information they provided would be held in confidence. Therefore, the FBI properly protected
the sources' identities and the information they provided pursuant to Exemption 7(D).
(b)(7)(D)-2: Names, Identifying Information of, and Information Provided by Individuals
under Expressed Assurances of Confidentiality
(96) Within Exemption category (b)(7)(D)-2, the FBI protected the names, identifying
information of, and information provided by third parties to the FBI under express grants of
confidentiality. When processing the records at issue, the FBI found evidence these individuals,
who provided specific and detailed information that is singular in nature, either requested their
identities not be revealed; and/or FBI investigators would have, by standard practice, expressly
promised these third parties their identities and the information they provided would remain
confidential.
(97) Providing express assurances of confidentiality is essential to the FBI's ability to
obtain relevant and accurate information from Cooperating Witnesses ("CWs"). This
designation of CW is a positive indication these individuals entered into official, confidential
relationships with the FBI in which they would have, by standard FBI practice, been provided
with express assurances of confidentiality. In sum, the FBI relied on certain individuals who
supplied information to the FBI with express assurance their names, identifying information, and
the information they provided would be held in confidence. Release of such information would
endanger these confidential sources and cause great detriment to the FBI's ability to recruit and
maintain reliable confidential sources; thus, the FBI protected this information pursuant to
Exemption 7(D).
(b)(7)(D)-3: Foreign Government Agency Information under Implied Confidentiality
(98) In Exemption category (b)(7)(D)-3, the FBI protected information provided to the
FBI from a foreign agency under circumstances in which confidentiality can be inferred. The
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=== Page 44 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
FBI, in connection with a wide variety of criminal and national security investigations, solicits
and receives information regularly from state, local, and foreign agencies and authorities.
Inherent in the cooperative effort is the mutual understanding that the identity of such a source
and the information provided by it will be held in confidence by the FBI, and not released
pursuant to FOIA requests. If disclosure of the information provided in confidence were to be
made public pursuant to FOIA requests, cooperation between the FBI and the foreign agencies
and authorities would be greatly diminished, causing great detriment to effective law
enforcement. The release of official United States Government documents that reveal the
existence of a confidential relationship with a foreign government reasonably could be expected
to strain relations between the United States and the foreign government and lead to diplomatic,
political or economic retaliations. A breach of this relationship can be expected to have at least a
chilling effect on the free flow of vital information to the United States law enforcement
agencies, which may substantially reduce their effectiveness. Accordingly, the FBI properly
withheld this information under FOIA Exemption 7(D).
(b)(7)(D)-4: Information Provided by Local Law Enforcement Agency
(99) Within Exemption category (b)(7)(D)-4, the FBI protected the names, identifying
information of, and information provided by local law enforcement personnel under an implied
assurance of confidentiality. Certainly, the FBI does not infer that all state or local law
enforcement authorities who cooperate in federal investigations do so with expectations of
confidentiality. However, under some circumstances, such an expectation may be inferred.
Here, law enforcement authorities provided specific detailed information of value to the FBI, that
is singular in nature, concerning Jeffrey Epstein. The FBI inferred these personnel provided this
information to the FBI with an expectation their involvement in the investigation, and/or the
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=== Page 45 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
information they provided, would remain confidential due to the following: the information
provided pertains to unknown investigations pursued by these agencies; or the information would
expose the agency's personnel to undue public scrutiny based on their involvement with these
particular matters.
(100) The FBI relies heavily on assistance from its state and local law enforcement
partners in pursuing its law enforcement and intelligence gathering missions. The disclosure of
this information could have disastrous consequences. If this information were released to the
public under FOIA, these agencies would be less likely to freely share sensitive information with
the FBI. It could also harm the FBI's ability to seek support and or assistance from these
agencies during joint investigations. Additionally, the FBI's disclosure of such information
could 1) jeopardize these agencies' investigative techniques and procedures as disclosure would
allow criminals to predict and circumvent use of these techniques and procedures; 2) discredit
these state and local law enforcement authorities with current and future confidential sources,
and greatly hinder their ability to recruit their own valuable sources; and 3) would jeopardize
unknown investigations pursued by these agencies. Accordingly, it is reasonable for the FBI to
infer these state and local law enforcement authorities provided this information to the FBI under
circumstances in which an assurance of confidentiality can be implied. Thus, this information is
exempt from disclosure pursuant to FOIA Exemption 7(D).
EXEMPTION 7(E)
INVESTIGATIVE TECHNIQUES AND PROCEDURES
(101) 5 U.S.C. § 552(b)(7)(E) provides protection for:
law enforcement records [which]...would disclose techniques and
procedures for law enforcement investigations or prosecutions, or
would disclose guidelines for law enforcement investigations or
prosecutions if such disclosure could reasonably be expected to risk
circumvention of the law.
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=== Page 46 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
(102) Exemption (b)(7)(E) has been asserted to protect information from these records,
the release of which would disclose techniques and/or procedures for law enforcement
investigations or prosecutions, or would disclose guidelines for law enforcement investigations
or prosecutions if such disclosure could reasonably be expected to risk circumvention of the law.
(103) Within the responsive documents, the FBI applied Exemption (b)(7)(E) to non-
public investigative techniques and procedures utilized by the FBI to pursue its law enforcement
mission, and also to non-public details about techniques and procedures that are otherwise
known to the public. Specifically, the FBI asserted Exemption 7(E) to protect the following
categories of information.
(b)(7)(E)-1: Collection and Analysis of Information
(104) In Exemption category (b)(7)(E)-1, the FBI protected the methods the FBI uses to
collect and analyze information it obtains for investigative purposes. The release of this
information would disclose the identity of methods used in the collection and analysis of
information, including how and from where the FBI collects information and the methodologies
employed to analyze it once collected. Such disclosures would enable subjects of FBI
investigations to circumvent similar currently used techniques. The relative utility of these
techniques could be diminished if the actual techniques were released in this matter. This in turn
would facilitate the accumulation of information by investigative subjects regarding the
circumstances under which the specific techniques were used or requested and the usefulness of
the information obtained. Release of this type of information would enable criminals to educate
themselves about the techniques employed for the collection and analysis of information and
therefore allow these individuals to take countermeasures to circumvent the effectiveness of
these techniques and to continue to violate the law and engage in intelligence, terrorist, and
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=== Page 47 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
criminal activities. Accordingly, the FBI has properly withheld this information pursuant to
FOIA Exemption 7(E).
(b)(7)(E)-3: Sensitive File Numbers
(105) In Exemption category (b)(7)(E)-3, the FBI protected sensitive investigative file
numbers. The FBI determined this Exemption is appropriate for protecting these file numbers as
the release of file numbering convention identifies the investigative interest or priority given to
such matters. The file numbers the FBI protected are not known to the general public. These file
numbers contain three separate portions. The first portions of these file numbers consist of FBI
file classification numbers which indicate the types of investigative/intelligenc gathering
programs to which these files pertain. Many of the FBI's classification numbers are public,
which makes disclosure of this information even more telling. Release of known file
classification numbers in the context of investigative records would immediately reveal the types
of investigations being pursued, and thus the types of investigative techniques and procedures
available to FBI investigators, and/or non-public facets of the FBI's investigative strategies. For
example, revealing that the FBI has a money laundering investigative file on a subject who was
only known to be investigated for crimes related to public corruption would reveal key non-
public information about the FBI's investigative strategies and gathered evidence. Additionally,
releasing non-public FBI file classification numbers would reveal critical information about non-
public investigative techniques and procedures, and provide criminals and foreign adversaries the
ability to discern the types of highly sensitive investigative strategies the FBI is pursuing
whenever such file classification numbers are present within these and other sensitive FBI
investigative records.
(106) The protected investigative file numbers also contain two letter office of
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=== Page 48 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
origination codes, indicating which FBI field office or overseas FBI legal attaché originated the
investigations at issue. Providing this information, in many instances, would provide critical
information about where and how the FBI detected particular criminal behaviors or national
security threats, and reveal key pieces about the FBI's non-public FBI investigations or
intelligence/evidence gathering sources and methods. Revealing this information could also risk
disclosing unknown FBI investigations or intelligence gathering initiatives, by revealing interests
in varying areas of FBI investigative responsibility. Releasing this information could also
possibly provide significant information about the FBI's failure to detect certain types of
criminal behavior. For example, a criminal operating out of San Francisco, California with ties
to a criminal organization under investigation in the FBI's Seattle Field Office could request the
FBI's Seattle Field Office's investigative file. If the FBI were to reveal all of the originating
office codes in the investigative files present in Seattle's file, and there was no indication the FBI
ever pursued an investigation in San Francisco, the criminal could reasonably assume the FBI
failed to locate any evidence of their wrongdoing, emboldening them to continue their activities,
undeterred.
(107) The third portion of these investigative files consists of the numbers given to the
unique investigative initiatives these files were created to memorialize. Releasing these singular
file numbers would provide criminals and foreign adversaries with a tracking mechanism by
which they can place particular files/investigations within the context of larger FBI investigative
efforts. Continued release of sensitive investigative file numbers would provide criminals with
an idea of how FBI investigations may be interrelated and when, why, and how the FBI pursued
different investigative strategies. This would provide criminals with a means of judging where
the FBI allocates its limited investigative resources, how the FBI responds to different
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=== Page 49 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
investigative circumstances, what the FBI knows and when/how they obtained the knowledge,
and if there are knowledge-gaps in the FBI's gathered intelligence.
(108) In summary, repeatedly releasing sensitive FBI investigative file numbers would
allow determined criminals and foreign adversaries to obtain an exceptional understanding of the
body of investigative intelligence available to the FBI; and where, who, what and how it is
investigating certain detected activities. Release of this information would enable these
criminals and foreign adversaries to predict FBI investigations and structure their behavior to
avoid detection and disruption by FBI investigators, enabling them to circumvent the law.
Accordingly, the FBI properly asserted FOIA Exemption 7(E) to protect this type of information.
(b)(7)(E)-4: Dates/Types of Investigations
(109) In Exemption category (b)(7)(E)-4, the FBI protected information pertaining to
the type of investigation referenced in the records at issue in this case. Specifically, some of the
information withheld, when referenced in connection with an actual investigation and not in
general discussion, pertains to the type of investigation, whether it is a "preliminary" or "full"
investigation and the dates the FBI initiated the investigations. Disclosure of this information
would inform criminals the types of activities that would trigger a full investigation as opposed
to a preliminary investigation, and the particular dates the investigations cover. Additionally,
this information would also give criminals valuable insight into how the FBI develops its
investigations. Release of this information would allow investigative subjects to predict FBI
investigative strategies and adjust their behavior accordingly. Moreover, revealing that a specific
activity in general warrants investigation could likewise cause individuals to adjust their conduct
to avoid investigative scrutiny by the FBI. Disclosure of information related to the type of
investigation could enable criminals to time and structure their illegal activities accordingly to
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=== Page 50 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
circumvent the FBI's attempts to enforce federal laws; therefore, the FBI has properly withheld
this information pursuant to Exemption 7(E). Accordingly, the FBI asserted this Exemption
category, at times in conjunction with Exemptions 3, 6, and 7(C) to protect names and
identifying information of third parties.
(b)(7)(E)-5: Information Regarding Target, Dates, and Scope of Surveillance
(110) In Exemption category (b)(7)(E)-5, the FBI protected information concerning the
target, dates, and scope of the surveillance operation conducted by the FBI in relation to the
investigation at issue here. The FBI utilized this surveillance operation to obtain investigative
intelligence relevant to the investigation of Jeffrey Epstein. Certainly, it is publicly known that
the FBI and other law enforcement agencies engage in different types of surveillance in
investigations. However, disclosure of non-public details about who, when, how, and under
what circumstances the FBI conducts surveillance would allow current and future subjects of
FBI investigations and other potential criminals to develop and utilize countermeasures to defeat
or avoid different types of surveillance operations, thus rendering the techniques useless to the
FBI and other law enforcement agencies. This is especially true because the success of
investigative surveillance hinges on investigators' abilities to remain undetected. Revealing any
non-public details about the FBI's methodology for conducting surveillance could potentially
jeopardize the FBI's ability to operate surveillance covertly, and risks circumvention of the law.
Accordingly, the FBI properly asserted Exemption 7(E) to withhold this information.
(b)(7)(E)-6: Information Contained in Effectiveness Rating FD-515
(111) In Exemption category (b)(7)(E)-6, the FBI protected certain sensitive
investigative information located within standardized FBI FD-515 forms. FD-515's are forms
used by FBI personnel to report investigative accomplishments. FD-515s are submitted at
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=== Page 51 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
various stages of an investigation to report important events such as an arrest, conviction,
sentencing, asset seizure, and disruption/dismantlement of a criminal enterprise. The FBI
asserted Exemption 7(E) to protect from disclosure statistical information concerning
effectiveness ratings assigned to various FBI investigative techniques. At the upper right-hand
side of this form is a block captioned "Investigative Assistance and Techniques Used." This
block lists numerous publicly known investigative techniques and assistances, some of which
were used by the investigative personnel during the FBI's investigation of Jeffrey Epstein.
Opposite each investigative technique and assistance is a rating column which records a
numerical rating from 1 to 4 to rate each technique/assistance used by investigative personnel
during the course of the investigation. The numerical rating evaluates the effectiveness of each
technique/assistance used in bringing the investigation to a successful conclusion. The entire
rating column has been deleted to protect from release the various techniques and assistance
used, and their effectiveness in the investigation. If the rating columns were released along with
the ratings of each technique and assistance used, others involved in similar criminal activities
could change their methods and modus operandi in order to circumvent and avoid detection
and/or disruption by FBI investigators, through the use of these techniques, in the future. The
protection of these rating columns is essential to prevent future circumvention of the law by
criminals. Therefore, the FBI properly protected this information pursuant to FOIA Exemption
7(E).
(112) Additionally, the FBI asserted Exemption 7(E) to withhold the "Assisting
Agencies" portions of the FD-515s within the responsive records. This was done to neither
confirm nor deny if any other federal, state, or local agencies assisted the FBI in law enforcement
activities. This is standard RIDS processing policy for all FD-515 Accomplishment Reports and
51
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=== Page 52 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
associated documents. Affirmatively acknowledging which law enforcement agencies (whether
state, local, or federal) assisted the FBI in its investigative efforts of the subjects of FD-515s
risks confirming unknown investigative interests of other law enforcement agencies by revealing
these other agencies' interests in the subject. Such revelations would allow subjects to predict
law enforcement actions, modify their behavior in a manner which avoids the investigative
efforts of law enforcement, and enable them to circumvent the law. Furthermore, if this portion
of the FD-515 is blank, thus revealing no other agencies assisted the FBI, criminals would be
able to discern if some of their criminal behaviors have gone undetected. This risks emboldening
such criminals to continue undetected criminal activities. It would also allow them to judge law
enforcement agencies' strengths and weaknesses in regards to detecting/disrupting particular
criminal activities; structure their activities to exploit this knowledge; and successfully evade law
enforcement agencies' efforts to enforce the law. Accordingly, only by employing the practice
of always redacting this portion of FD-515s is the FBI able to avoid the substantial law
enforcement circumvention risks enumerated above; thus, the FBI properly withheld this
information pursuant to FOIA Exemption 7(E).
(b)(7)(E)-7: Database Identifiers/Printouts
(113) In Exemption category (b)(7)(E)-7, the FBI protected the identities of sensitive
investigative databases and database search results located through queries of these non-public
databases used for official law enforcement purposes by the FBI. Releasing the identities of
these databases and any information located through queries of these databases would give
criminals insight into the available tools and resources the FBI uses to conduct criminal and
national security investigations (i.e., the scope of information stored within the databases, how
the FBI uses the databases to support its investigations, the types of information most valued by
52
EFTA00015270

=== Page 53 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
the FBI for particular investigations, and vulnerabilities of the databases).
(114) Revealing the use of these databases in the context of FBI investigative records,
and the information generated through queries of these databases, would reveal the nature of
their utility to FBI investigators and the scope of information stored within the databases.
Disclosing when and why the FBI queries these databases would reveal key information about
FBI investigative strategies. This is because different investigative databases contain varying
datasets and revealing the types of data sought by investigators in particular investigative
circumstances would reveal the FBI strategies employed in response to different investigative
circumstances. Additionally, disclosing the search results for particular subjects would provide
criminals with an understanding of the scope of FBI collected intelligence on particular subjects.
It would expose possible intelligence gaps and/or intelligence gathering strengths. This would
allow criminals to make informed decisions on how they might structure their behavior to exploit
these strengths and weaknesses and avoid detection and/or disruption by the FBI.
(115) Revealing the types of information stored in these databases would also reveal the
types of information most useful to FBI investigators. This would provide criminals with an
understanding of how they might structure their behavior and/or deploy countermeasures to
deprive the FBI of useful intelligence/evidence, thus jeopardizing the FBI's investigative
mission.
(116) Finally, revealing the identities of these databases could jeopardize the FBI's
investigative mission by revealing exactly where the FBI is storing and obtaining valuable
investigative data. Knowing the database names makes the original source data an attractive
target for compromise. It would allow criminals who gain access to FBI systems an idea of
where they can go to discover what the FBI knows, how it gathered the information, and possible
53
EFTA00015271

=== Page 54 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
information regarding the FBI's investigative strategies. It would also offer these criminals the
opportunity to corrupt or destroy information stored within these databases.
(117) In summary, release of this information relative to FBI investigation databases
impedes the FBI's effectiveness and potentially aids in circumvention of valuable investigative
techniques. Therefore, the FBI withheld this information pursuant to Exemption 7(E).
(b)(7)(E)-9: Monetary Payments/Funding for Investigative Purposes
(118) In Exemption category (b)(7)(E)-9, the FBI protected information about monetary
amounts requested by FBI personnel and/or paid by the FBI in order to implement particular
investigative techniques. The FBI has limited resources that it must allocate strategically in
order to effectively pursue its law enforcement and intelligence gathering missions. Revealing
the amount of money the FBI has paid or plans to pay in order to implement certain investigative
techniques would reveal the FBI's level of focus on certain types of law enforcement or
intelligence gathering efforts and priority given to certain investigative matters. Revealing this
level of focus would reveal how the FBI plans to allocate its limited resources and essentially
paint a picture as to where the FBI's strengths and weaknesses lie within the spectrum of illegal
activities it is mandated to investigate. Releasing this information would give criminals the
opportunity to structure their activities in a manner which avoids the FBI's strengths and exploits
its weaknesses. Because release of this type of information would enable criminals to
circumvent the law, this information has been properly withheld pursuant to Exemption 7(E).
WITHHOLDING OF DOCUMENTS UNDER A SEALED COURT ORDER
(119) The FBI has withheld 38 pages in full per a Court Order issued by the United
States District Court for the Southern District of Florida in Case Number 08-mj-08068-LRJ. The
FBI searched for any unsealing order in the Public Access to Court Electronic Records
54
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=== Page 55 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
("PACER"), and the records responsive to Plaintiffs' request are still sealed. Therefore, the FBI
withheld responsive information subject to the sealing order, which precludes release of the
following pages by the FBI: Bates pages 03956-1033 through 03956-1070. Due to the sealing
order, these pages were not reviewed for applicable FOIA exemptions. Should the court lift the
sealing order, the FBI respectfully requests an opportunity to assert applicable FOIA exemptions.
SEGREGABILITY
(120) As discussed in 4 supra, the FBI processed a total of 11,571 responsive pages
within the category of Bates-stamped records: 181 were released in full ("RIF"), 1,051 were
released in part ("RIP"), and 10,339 were withheld in full ("WIF"). Each of these categories is
discussed below to further address segregability.
a. Pages RIF. Following its segregability review, RIDS determined 181
pages could be released in full without redaction as there was no
foreseeable harm to an interest protected by a FOIA exemption.
b. Pages RIP. Following its segregability review, RIDS determined 1,051
pages could be released in part with redactions per the identified FOIA
exemptions herein. These pages comprise a mixture of material that could
be segregated for release and material that was withheld as release would
trigger foreseeable harm to one or more interests protected by the cited
FOIA exemptions on these pages.
c. Pages WIF. Following its segregability review, RIDS determined 10,339
pages required withholding in their entirety. RIDS determined all
information on these pages was either fully covered by one or more of the
cited FOIA exemptions or determined that any non-exempt information on
55
EFTA00015273

=== Page 56 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
these pages was so intertwined with exempt material, no information could
be reasonably segregated for release. Any further segregation of this
intertwined material would employ finite resources only to produce
disjointed words, phrases, or sentences, that taken separately or together,
would have minimal or no informational content. Additionally, the FBI
withheld 38 pages because they were deemed to be currently sealed
pursuant to a United States District Court order, as described at " 113,
supra. Also, the FBI withheld 123 pages because they were duplicates of
pages accounted for elsewhere in the FBI's production. It is the FBI's
standard practice not to process duplicate pages, as doing so expends finite
processing resources with a net result of no additional information being
released to requesters.
CONCLUSION
(121) The FBI performed adequate and reasonable searches for responsive records;
processed all such records and released all reasonably segregable non-exempt information from
documents responsive to Plaintiffs' FOIA request that are subject to FOIA. The FBI processed
the records under the access provisions of the FOIA to achieve maximum disclosure.
Information was properly withheld pursuant to FOIA Exemptions 3, 5, 6, 7(A), 7(C), 7(D), and
7(E). The FBI carefully examined the documents and determined the information withheld from
Plaintiffs in this case, if disclosed, would reveal statutorily protected information; would reveal
privileged information; could reasonably be expected to interfere with pending or prospective
enforcement proceedings; would cause a clearly unwarranted invasion of personal privacy, or
could reasonably be expected to constitute an unwarranted invasion of personal privacy; could
56
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=== Page 57 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
reasonably be expected to disclose the identities of confidential sources and the information they
provided; and/or would disclose techniques and procedures for law enforcement investigations.
After extensive review of the documents at issue, I have determined that there is no further non-
exempt information that can be reasonably segregated and released without revealing exempt
information.
Pursuant to 28 U.S.C. $ 1746, I declare under penalty of perjury that the foregoing is true
and correct, and that Exhibits A through EE attached hereto are true and correct copies.
57
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=== Page 58 ===
Author: CGM
Reviewed: TLC 3/10/21, 3/11/21
Deliberative Process/Attorney-Client/Attorney Work Product Privileged
Executed this
day of June 2021.
MICHAEL G. SEIDEL
Section Chief
Record/Information Dissemination Section
Information Management Division
Federal Bureau of Investigation
Winchester, Virginia
58
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=== Page 1 ===
From:
To:
Subject: RE: grand jury
Date: Tue, 23 Jun 2020 02:32:08 +0000
Attachments: Maxwell,_Ghislaine_Transcript_(04-22-16).pdf Maxwell,_Ghislaine_Transcript_(07-22-
16).pdf
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?
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?
EFTA00017703

=== Page 2 ===
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
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.
EFTA00017704

=== Page 3 ===
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.
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
EFTA00017705


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
=
Subject: Stay motion
Date: Fri, 28 Aug 2020 01:26:14 +0000
Attachments: 2020.08.27_Letter.pdf
Attached is the plaintiff's opposition to the stay.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00016285


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=== Page 1 ===
User: AJUSTICE
PALM BEACH POLICE DEPARTMENT
08/11/2020
FLORIDA CITATION REPORT
Citation #: 010398P
Related Case #:
Court Information
Court: Criminal Justice Complex
Date/Time:
3228 GUN CLUB ROAD
Violator
Name: Maxwell, Ghislaine
Race: W
Sex: F
DOB:
Age: 34
Address:
Phone #:
PALM BEACH, FL 00003-3480
DL #/State:
UK
Employer:
Vehicle Information
Lic. Plate #/State: RAS85L FL
Lic. Year: 0
Vehicle Type: AUTOMOBILE
Veh. Year: 1986
Make: MERZ
Model:
Citation Information
Citation Date: January 13, 1996, Saturday
Time: 15:10
Issued On:
Issued By: (999000)
Agency: PBPD
District:
Location:
PALM BEACH
Unlawful Speed:
Applicable Speed: 0
BAC:
Charge: TC037 DRIVER LICENSE NOT CARRIED
Officer Notes
HTE Case Reference #: (196000000).
Issued By: (0280650)
Entered By: (0279290)
Search Information: SHIFT 2
HTE Ordinance #: 322.15
r_citafl
EFTA00016522

=== Page 2 ===
User: AJUSTICE
PALM BEACH POLICE DEPARTMENT
08/11/2020
FLORIDA CITATION REPORT
Citation #: 45195
Related Case #:
Court Information
Court: Criminal Justice Complex
Date/Time:
3228 GUN CLUB ROAD
Violator
Name: Maxwell, Ghislaine
Race: W
Sex: F
DOB:
Age: 34
Address:
Phone #:
PALM BEACH, FL 00003-3480
DL #/State:
UK
Employer:
Vehicle Information
Lic. Plate #/State: RAG85Z FL
Lic. Year: 0
Vehicle Type: AUTOMOBILE
Veh. Year: 1986
Make: MERC
Model:
Citation Information
Citation Date: January 13, 1996, Saturday
Time: 15:10
Issued On:
Issued By: (999000)
Agency: PBPD
District:
Location:
PALM BEACH
Unlawful Speed:
Applicable Speed: 0
BAC:
Charge: TC004 WRITTEN WARNING TRAFFIC
Officer Notes
HTE Case Reference #: (196000000).
Issued By: (0280650)
Search Information: SHIFT 2
HTE Ordinance #: PASSING DOUBLE YELLOW
Citation Intersection: COCOANUT ROW PALM BEACH, FL 000033480
r_citafl
EFTA00016523

=== Page 3 ===
User: AJUSTICE
PALM BEACH POLICE DEPARTMENT
08/11/2020
FLORIDA CITATION REPORT
Citation #: 48058
Related Case #:
Court Information
Court: Criminal Justice Complex
Date/Time:
3228 GUN CLUB ROAD
Violator
Name: Maxwell, Ghislaine
Race: W
Sex: F
DOB:
Age: 34
Address:
Phone #:
PALM BEACH, FL 00003-3480
DL #/State:
UK
Employer:
Vehicle Information
Lic. Plate #/State: RAS85L FL
Lic. Year: 0
Vehicle Type: AUTOMOBILE
Veh. Year: 1986
Make: MERC
Model:
Citation Information
Citation Date: August 10, 1996, Saturday
Time: 05:05
Issued On:
Issued By: (999000)
Agency: PBPD
District:
Location: ROYAL PALM WY, PALM BEACH
Unlawful Speed:
Applicable Speed: 0
BAC:
Charge: TC004 WRITTEN WARNING TRAFFIC
Officer Notes
HTE Case Reference #: (196000000).
Issued By: (0273160)
Entered By: (0279360)
Search Information: SHIFT 2
HTE Ordinance #: NO LEFT TURN
Citation Intersection: S COUNTY RD PALM BEACH, FL 000033480
r_citafl
EFTA00016524


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=== Page 1 ===
11/28/21, 9:27 PM
Mail
(NY) (FBI) Outlook
Fwd: RE: Epstein HDs
Wed 10/14/2020 7:04 AM
To:
has been coordinating with
She's the POC.
On Oct 14, 2020 11:29 AM,
wrote:
Pls ensure that sdny is aware and knows how to access this stuff. Who can
reach out to at sdny in
NY to discuss?
Forwarded message
From:
Date: Oct 13, 2020 5:18 PM
Subject: RE: Epstein HDs
To:
>,
>
Cc:
(NY) (FBI)"
<
>,
>
All the devices and media have been available through our CAIR system for over a year. I suggest you
review through that system. I have already given several people access to those machines. I can add
more as needed. All the additional exports with the exception of 6 machines have been completed
and can be shipped over to Southern tomorrow. I'll be available in the afternoon after I get back from
the Bronx where ill be getting some information off some of the evidence that was already checked
back in and is now in storage. If any of this needs clarification, please feel free to call my cell so we
can discuss.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Oct 13, 2020 1:56 PM,
wrote:
Stephen -
is copied on this and will be your POC for this week since
is OCONUS.
Can you pls let us know your progress on these devices and how our folks can review them? Also, how many
devices are we looking at that will need to be reviewed by us? We are trying to set up resources to get through
them ASAP. SDNY has agreed to review some and we will review the remaining balance.
may have a few additional questions for you as well. She will reach out.
Thanks
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/2
EFTA00014973

=== Page 2 ===
11/28/21, 9:27 PM
Mail
(NY) (FBI) Outlook
From:
(NY) (FBI)
Sent: Friday, October 09, 2020 12:55 PM
To:
Cc:
is
Subject: Epstein HDs
Sounds good
is on top of this and will take care of it. If there are any other issues or
concerns, don't hesitate to reach out.
SSA
Forensic Examiner
CART/OS-19 New York
- office
- cell
On Oct 9, 2020 12:39 PM,
wrote:
Good talking to you today
is getting 3 - 2TB External HDs today and will leave them on
desk.
will Email
everyone when they are there for him. If you don't need the 3rd drive you can send it back to us.
On a rolling basis, can
let
know when the HDs are done so we can alert SDNY and
coordinate getting them over there. Given the attention this case is getting from EM we want to ensure
there are no delays/issues.
is OCONUS next week on this case so pls copy me on any update
has.
Appreciate everyone's help on this as usual.
Call or email with any questions
C
-
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
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=== Page 1 ===
From: Ted Leopold
To:
(USAFLS)"
Subject: RE: Epstein Investigation
Date: Mon, 30 Jun 2008 21:43:21 +0000
Importance: Normal
correct. Quite a story however. Makes you wonder what a guy like this is thinking.
Original Message
From:
(USAFLS) [mailto:
Sent: Monday, June 30, 2008 5:19 PM
To: Ted Leopold
Subject: RE: Epstein Investigation
I wish it had been more time, but this way the girls get some compensation without the horrors of a trial.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From: Ted Leopold [mailto:
Sent: Monday, June 30, 2008 5:23 PM
To:
(USAFLS)
Subject: RE: Epstein Investigation
ps, great job of not letting this guy off.
Original Message
From:
.
(USAFLS) [mailto:
Sent: Monday, June 30, 2008 5:13 PM
To: Ted Leopold
Subject: RE: Epstein Investigation
I will do so. Look forward to hearing from you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From: Ted Leopold [mailto:
Sent: Monday, June 30, 2008 5:13 PM
To:
(USAFLS)
Subject: RE: Epstein Investigation
Thanks
I will get back to you.
p.s., Tell
and
hello for me. Both are good friends for mine.
EFTA00014160

=== Page 2 ===
Original Message
From:
(USAFLS) [mailto:
Sent: Monday, June 30, 2008 5:00 PM
To: Ted Leopold
Subject: Epstein Investigation
Dear Ted: Here is my e-mail address and contact information.
Thank you for your assistance.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
EFTA00014161


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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 "Acknowledgment and Notice of Appearance FILED"
Date: Mon, 05 Apr 2021 18:03:09 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/05/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
ACKNOWLEDGMENT AND NOTICE OF APPEARANCE, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 04/05/2021 by CM/ECF.[3070408] [21-770]
Notice will be electronically mailed to:
,
Assistant U.S. Attorney:
David Oscar Markus, -:
, Deputy Clerk:
Notice will be stored in the notice cart for:
Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Acknowledgment and Notice of Appearance FILED
Original Filename: Acknowledgment and Notice of Appearance Form 4.5.21.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/05/2021] [FileNumber=3070408-0]
[b9eb9d3e7164a1dc27a0ef131ed6a87acd4e3a5d80d36f94eb28675440bea48debd0ebea062d359ce34193793ab0e
EFTA00015720

=== Page 2 ===
352c2c5c842ea871fb9a56540ffef23df9d]]
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=== Page 1 ===
10/6/21, 2:44 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Tonight's events
Date: Mon, 22 Jun 2020 12:47:10 +0000
Thank you for this lovely and heartfelt note. It has been a pleasure working with you on some of the Office's
most important cases, which would not have been possible without your tenacity and intelligence. I hope I am
able to see you before too long.
On Jun 21, 2020, at 7:13 PM,
wrote:
I very much look forward to a time when I can say this to you in person, but in the interim, thank you so, so much for
having the fortitude and courage to stand up for what is right for the interests of justice and the Office, both over the
course of years and especially in recent days. It obviously is no exaggeration to say that you have made the difference
between continuity and consistent principled leadership at SDNY and an entirely unknown alternative. It is truly
extraordinary.
More generally, although I'm dismayed that you won't be physically present for the charging and resolution of so many
cases you've put your heart and soul into, I am immensely grateful to have worked for you and we are all determined to
see through the cases that have been built during your tenure. And in particular, I'm personally so grateful for your
support, encouragement, and input on the Epstein case. A different U.S. Attorney might very well have said was too
difficult to pursue, or too aggressive to charge, or too old to relitigate - and instead, you have been with us every step of
the way. Even in challenging moments, when we all felt the immense pressure of the circumstances, it was always clear
that you were focused on the interests of justice and the interests of the victims. In a case that was incredibly tough but
even more rewarding, I hope you will take great pride in what the Office accomplished - and what we will continue to
attempt to achieve going forward.
And with all our cases, you always prioritized the most important parts of our work and upheld the best traditions of the
Office. On a personal note, I remember meeting you in the very first day or two you were on the job, when you walked
around the 8th floor on a weekend, introducing yourself and your family and wanting to connect with the AUSAs right
away. And you were the exact same up until what ended up being some of the last days, walking around on 8, checking
in on the people who came in for the first day of the readiness phase, and talking about the importance of integrating
people who wouldn't be able to be physically present for a while. Very fitting bookends.
I look forward to reunions for many years to come, I hope you and your family stay well given all the current
circumstances, and thank you very much for your leadership.
From:
Sent: Saturday, June 20, 2020 09:51
To:
Subject: RE: Tonight's events
EFTA00014382

=== Page 2 ===
I just wanted to briefly add to what I know is an outpouring of support, both within and outside our Office - yesterday's
events were unconscionable, and not least because of, and perhaps prompted by, your steadfast integrity and
leadership. You have consistently supported and upheld the highest standards of the Office, both substantively for our
work and also in terms of our processes and morale (I can't believe it was just Tuesday that we talking about how
thorough and effective the SDNY approach has been to COVID). Thank you for standing up for what is right, and for your
leadership now and in the future.
From:
Sent: Saturday, June 20, 2020 01:04
To:
Subject: Tonight's events
From the bottom of my heart, thank you for your many messages of support and encouragement. They mean the world
to me. Please know that my only concern is protecting this Office and your work. It is the privilege of a lifetime to be
your U.S. Attorney-and I will do everything in my power to honor the trust you have given me.
EFTA00014383


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=== Page 1 ===
10/6/21, 12:43 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/2
EFTA00015172

=== Page 2 ===
10/6/21, 12:43 PM
III/FBI/State Delayed Response
2/2
EFTA00015173


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=== Page 1 ===
From:
To:
Subject: Tentative: Epstein NY property
Date: Thu, 16 Jul 2020 15:59:37 +0000
Importance: Normal
Attachments: unnamed
EFTA00015961


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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: Call this week
Date: Tue, 31 Mar 2020 18:42:17 +0000
Sounds good, thanks
On Mar 31, 2020, at 2:40 PM,
)
wrote:
Awesome. I haven't been able to reach
by email or phone, but if that changes in the next 20 mins then we can
switch from my cell to conference line. Otherwise will give you a call as soon as I hear from Gloria.
From:
Sent: Tuesday, March 31, 2020 14:28
To:
Cc:
Subject: Re: Call this week
Yes, I can join.
On Mar 31, 2020, at 2:07 PM,
)
wrote:
Are either / both of you able to join? No problem if not, I can just receive the update, but great if you're around. If all
of us can do it, I'll switch the invite from my number to
conference line (I need a login reset for my
USAVoice account otherwise I'd use mine).
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:54
To:
)
Cc:
is
Subject: RE: Call this week
That works. Please advise as to which number I should call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
EFTA00016228

=== Page 2 ===
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:51 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Yes, if that works for you - so in a little more than an hour. Or let us know if there's a different preferable time.
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:50
To:
Cc:
is
Subject: RE: Call this week
3P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:46 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
That would be great, thanks. Would 3:00 work for you? Or please let us know if there's a more convenient time, we
can be flexible.
thanks again,
From: Gloria Allred
Sent: Tuesday, March 31, 2020 13:31
To:
)
Cc:
is
Subject: RE: Call this week
May I call you with an update? What time today are you available for a call?
EFTA00016229

=== Page 3 ===
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Tuesday, March 31, 2020 10:03 AM
To: Gloria Allred
Cc:
is
Subject: RE: Call this week
Gloria,
We were wondering if you or your colleagues have been able to reach any of the clients we discussed last week? It
would be very helpful to know their views and reactions shortly - and we're of course happy to speak with them
directly as well if that would be helpful.
thanks,
From:
Sent: Thursday, March 26, 2020 15:45
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM, Gloria Allred
wrote:
Thank you.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
EFTA00016230

=== Page 4 ===
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Thursday, March 26, 2020 7:12 AM
To: Gloria Allred
Cc:
>;
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
Thank you,
On Mar 25, 2020, at 8:55 PM, Gloria Allred
wrote:
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 5:53 PM
To: Gloria Allred
Cc:
is
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
On Mar 25, 2020, at 8:21 PM, Gloria Allred
wrote:
EFTA00016231

=== Page 5 ===
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's Hall of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To: Gloria Allred
Cc:
is
Subject: Call this week
Gloria,
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you
with a bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY
TELEPHONING THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
EFTA00016232

=== Page 6 ===
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00016233


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=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: travel approval request
Date: Fri, 14 Feb 2020 18:42:44 +0000
I'm always lookin out for the team! : )
From:
Sent: Thursday, February 13, 2020 16:33
To:
Cc:
is
>;
Subject: Re: travel approval request
We were able to book the Beverly Hilton at the government rate. Good find on that.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Thursday, February 13, 2020 8:03 AM
To:
Cc:
is
>;
Subject: Re: travel approval request
Ok thanks for looking into that we'll take a look on our side.
On Feb 13, 2020, at 01:24,
)
wrote:
Team, just as an FYI, no obligation at all for anybody else to do this, but I switched my L.A. hotel to a different spot for
our upcoming visit - at least through our booking systems, the DoubleTree in Santa Monica during that time is over our
allowable daily price for whatever reason - but even more importantly, last time we were there the front desk told me
that construction there was going to be a complete nightmare from January through at least March (i.e., all the drilling
from last time, but much worse). And I didn't see any other normal / decent business hotels in that area that were
within our per diem (with the possible exception of the Le Meridien).
However, for the first time in any of the trips we've ever been out there, the Beverly Hilton is listed within our per diem
($181 for the AUSAs), and it's less than a ten minute drive from both
attorney's office and
attorney's
office (and we could of course get a conference room there for
).
It's not the fanciest hotel in the world, but it's a
normal Hilton, the location is perfect, and no drilling (!), so I went for it and wanted to recommend it and let everybody
know. No worries if people prefer elsewhere, but it's an option.
EFTA00014385

=== Page 2 ===
From:
Sent: Thursday, February 13, 2020 01:15
To:
Cc:
is
Subject: FW: travel approval request
just FYI, in connection with this trip to Los Angeles, I just made a reservation for a hotel on E2 (see attached) -
if I did anything wrong, it can be changed, but it's a hotel that is almost never available for us so I wanted to make the
reservation tonight just in case. And will follow up with flights in the coming days. Happy to chat if that's useful, and
thanks very much.
From:
Sent: Wednesday, February 12, 2020 22:55
To:
Cc:
is
is
(
Subject: Re: travel approval request
Approved
Sent from my iPad
On Feb 12, 2020, at 9:14 PM,
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for three interviews in Los Angeles on February 26, 27, and 28 (we have at
least one interview on each of those days). We expect to be traveling, respectively, some combination of the 25th to
the 29th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those dates (the
26th).
thank you,
<mime-attachment>
EFTA00014386


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=== Page 1 ===
From:
To:
Subject: FW: Ghislaine Maxwell- 02879-509
Date: Wed, 13 Oct 2021 13:32:30 +0000
Don't think we need to bother team with this, but FYI.
From:
Sent: Wednesday, October 13, 2021 8:38 AM
To:
Subject: RE: Ghislaine Maxwell- 02879-509
Thanks!
=
)"
> 10/13/2021 8:37 AM >>>
Hi
Yes, I relayed our last conversations to the AUSAs after we spoke. Defense counsel continues to press (with us as well) for
delivery requirements that are inconsistent with the way we understand other defendants' mail to be treated and the way
we typically treat mail bound for in-custody defendants. Happy to discuss by phone.
Thanks,
From:
Sent: Wednesday, October 13, 2021 6:56 AM
To:
Subject: Fwd: Ghislaine Maxwell- 02879-509
Did you discuss with the AUSAs about tempering expectations on the delivery of the hard drives?
>>> BOBBI C STERNHEIM
> 10/12/2021 10:25 AM >>>
Good morning-
The government has sent a hard drive to the MDC via Federal Express for Ms. Maxwell.
Upon arrival, it must IMMEDIATELY be given to Ms. Maxwell.
Time is of the essence.
Please inform me when it arrives.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
EFTA00016716

=== Page 2 ===
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00016717


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(USANYS)"
)"
,
)"
Subject: Palm Beach
Date: Thu, 07 Oct 2021 21:01:34 +0000
Attachments: Pages_from_PB_76-2.pdf; 2021.10.07_Subpoena_to_PBPD.pdf
and
The report we discussed is attached. The first four pages concern activities in 2001-2002, but the reports that follow
appear to have similar reference numbers through 2004, so I'm including for context in case that assists you in sorting this
out tomorrow. The contact to reach out to is Sgt.
His work number is
,
but if he said if you can't
reach him on that number please call his personal number:
We recognize you're still working out logistics for travel tomorrow morning, but whenever you have a sense of timing and
which one of you will by flying out, please let us know when you can.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00015175


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=== Page 1 ===
From:
To:
Subject: FW: Maxwell info
Date: Thu, 16 Jul 2020 17:41:17 +0000
For you.
From: Parry, Emma
>
Sent: Thursday, July 16, 2020 1:26 PM
To:
Subject: Maxwell info
Hi
I'm not sure if you are the right person to speak to so please redirect this email if necessary.
I am a reporter at The Sun and I recently did an interview with a source who has a lot of information about
Ghislaine Maxwell and Jeffrey Epstein. He is currently in prison but has cooperated on other cases with ATF and
now wants to cooperate with authorities on the Maxwell case. I believe he is credible.
He named many names to me which we didn't publish but he is happy to share with investigators.
https://www.thesun.co.uk/news/12091701/epstein-maxwell-people-sex-under-age-girls/
He has asked me to reach out to help facilitate this.
Can you help? Or advise on how I should proceed?
Thanks
Emma
Emma Parry
Digital US Correspondent, The Sun
www.the-sun.com
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
registered office at 1 London Bridge Street, London, SE1 9GF and
is registered with VAT number GB 243 8054 69. If you have received
this e-mail in error, please notify the sender immediately and do not
use, distribute, store or copy it in any way. Statements or opinions in
this e-mail or any attachment are those of the author and are not
necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It accepts
no liability for viruses introduced by this e-mail or attachments.
EFTA00015966

=== Page 2 ===
News Corp UK & Ireland Limited and its titles are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
EFTA00015967


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=== Page 1 ===
From: "
To:
)"
Subject: RE:
Date: Wed, 24 Nov 2021 16:57:51 +0000
Inline-Images: image001.jpg
Thank you, all set here
From:
Sent: Wednesday, November 24, 2021 11:57 AM
To:
Subject: RE:
Still stamped thanks
From:
Sent: Wednesday, November 24, 2021 11:54 AM
To:
Subject: RE:
Thanks, they've been added, but lastly just wanted to check whether they should be marked with our confidential stamp
or not, since they've been publicly filed?
From:
Sent: Wednesday, November 24, 2021 11:38 AM
To:
Subject: RE:
Just the attachment, thanks
From:
Sent: Wednesday, November 24, 2021 11:27 AM
To:
Subject: RE:
Do you just want the attachments added, or should the email below be added too?
From:
Sent: Wednesday, November 24, 2021 11:02 AM
To:
Subject: FW:
For
3500. Thanks.
From: Joe Nascimento
Sent: Tuesday, November 23, 2021 11:38 PM
To:
Subject: [EXTERNAL]
EFTA00014881

=== Page 2 ===
Hi Alison,
I wanted to alert you to a recent development.
was recently served with a subpoena for a deposition in Melissa
Selinger V. Kimera Labs,
Alexander Jelinek (20-cv-24267).
ex-husband
is being sued by a
former employee on several grounds including sex discrimination, battery and IIED.
is getting dragged in because
they want to connect
to
actions while working for Epstein.
The depo was set for November 30. The Defendants filed a motion to quash (attached), which the court granted and
stayed the depo. The Plaintiff has filed a motion to reconsider (attached), and the Court has ordered the Defendant to
respond. The Plaintiffs have included a copy of the NPA,
depo and have made numerous factual allegations
related to Epstein in their motion.
l'll keep you updated as I learn more.
Have a Happy Thanksgiving,
Joe
Joseph E. Nascimento, Esq.
AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
AMSEL RABEN
NASCIMENTO
EFTA00014882


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Date: Tue, 17 Dec 2019 14:15:07 +0000
Thanks again for taking the lead on this stuff. I'll be in a meeting from about 10:30am to 3pm today, but otherwise am
available if there's anything you want to discuss before tomorrow's conference. I have a 10am plea in White Plains
tomorrow, so I'm planning to take the train up.
From:
USANYS)
Sent: Tuesday, December 17, 2019 6:47 AM
To: Aida Leisenring <aleisenring@barketepstein.com>
Cc:
>; Bruce Barket <bbarket@barketepstein.com>
Subject: Re: Follow Up on July 23 Incident Sensitive Disclosure Materials
Aida,
To confirm, we are looking into whether video of the hallway, and videos and/or photos of the cell exist. We likely would
make those available for review in the same manner as the report. We are also looking into whether the orange rope was
preserved and if it was, we will let you know our position on whether it can be made available for inspection. As discussed
briefly, since you have reviewed a photograph of the rope, we are not sure the basis for a physical inspection and would
ask you to articulate one for our consideration.
Co-Chief, Narcotics Unit
On Dec 16, 2019, at 16:52, Aida Leisenring <aleisenring@barketepstein.com> wrote:
Hello
Thank you for taking the time to let us review sensitive disclosure materials in your office on Friday. We appreciate it. I
just wanted to memorialize a few follow-up questions we had.
1. It is our understanding that there is video surveillance in the hallway in or near the tier that was preserved in
reference to the July 23 incident. We would like to see a copy of it.
2. It is our understanding that there may be photographs or a video recording of cell 124 that would have been
taken shortly after the incident. If so, we would like to see them.
3. If the orange rope was preserved, we would like to view it in person.
I understand that you were not aware of the availability of the above and that you would look into this additional
discovery. I just wanted to memorialize our follow up inquiries for your records.
Lastly, if the items above are available, does your office take a position with respect to our request to view them? We
just need to know so we can plan our next course of action.
See you in Court, and thank you again for your time.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
666 Old Country Road, Ste 700
EFTA00016401

=== Page 2 ===
Garden City, NY 11530
T
F
Please note that my emailed has changed to:
aleisenring@barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments.
EFTA00016402


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=== Page 1 ===
From:
=
To:
Subject: Accepted: Call/Meeting on Epstein
Date: Fri, 07 Dec 2018 03:33:13 +0000
Importance: Normal
Attachments: unnamed
EFTA00014908


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=== Page 1 ===
From: Nathan NYSD Chambers
To:
Subject: 20cr330, US V. Maxwell
Date: Wed, 01 Dec 2021 04:06:59 +0000
Attachments: 20cr330_Order_11.30.21.pdf
Counsel:
Attached please find an Order issued by the Court. The Court will discuss with the parties tomorrow if there is
any basis to seal the Order.
Please confirm receipt.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00016588


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=== Page 1 ===
From:
To: "ROBERT C. JOSEFSBERG"
Subject: RE: call
Date: Sun, 07 Jul 2019 01:21:41 +0000
Importance: Normal
Unfortunately information about the arrest of Jeffrey Epstein has leaked to the media while we were still in the process of
trying to reach out to victims and their counsel, but I nevertheless wanted to reach out to you directly - could you please
give me a call at your earliest convenience and I can let you know the current status, so you can pass it along to your
client(s)? I'm reachable anytime day or night at
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein case, SDNY
Date: Sun, 14 Jul 2019 04:08:59 +0000
Importance: Normal
Team - following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My
colleagues
and
are also working on the case, and they're copied here and we're all reachable
at these email addresses or by phone anytime at:
We greatly appreciated
being willing to talk with us, and I expect we'll be in touch again in the coming weeks.
And of course if anything comes up that you want to reach out to us about, please don't hesitate at all.
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: RE: financial documents (Epstein)
Date: Thu, 18 Jul 2019 22:55:47 +0000
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
Cc:
is
(NY) (FBI)
in
is
is
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,
wrote:
I have the discs, where should I bring them?
From:
Sent: Wednesday, July 17, 2019 8:47 PM
To: Hamilton,
)
[Contractor] <AHamilton@usa.doj.gov>
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
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNY
investigation\Subpoena Returns\Deutsche_Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
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.
EFTA00014611

=== Page 2 ===
thanks,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00014612


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=== Page 1 ===
90A-NY-3151227 Serial 51
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/22/2019
Evidence NYC023597
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC023597: One (1) Hitachi 2TB
Hard Drive, 0F10311JPK3EA0P09, S/N B9GMGTYF, containing the verified E01
images NYC023589 (1B12), NYC023593 (1B16), NYC023594 (1B17), and
NYC023595 (1B18). Master Copy.
Item Type
Description
1B Digital
(U) One (1) Hitachi 2TB Hard Drive, 0F10311JPK3EA0P09,
S/N B9GMGTYF, containing the verified E01 images
NYC023589 (1B12), NYC023593 (1B16), NYC023594 (1B17),
and NYC023595 (1B18). Master Copy.
Collected On: 08/21/2019 04:00 PM EDT
Seizing Individual:
R
Collected By:
R
Device Type: Hard Drive
Designation: Master Copy
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00015842

=== Page 2 ===
90A-NY-3151227 Serial 51
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC023597
Re: 90A-NY-3151227, 08/22/2019
UNCLASSIFIED
2
EFTA00015843


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=== Page 1 ===
From: Ryan Hooper <Ryan.Hooper@pa.media>
To:
Subject: [EXTERNAL] US V Maxwell - press query
Date: Wed, 20 Oct 2021 13:49:49 +0000
Hello all,
I am a journalist with the Press Association in London.
Is there anyone who might be able to outline whether the trial of US V Ghislaine Maxwell is due to open, as planned, on
November 29 please?
Also looking to try and find out whether the defendant is due to give evidence, and how long the trial is listed for.
Have had no joy getting hold of anyone at the court (212 637 2600).
Apologies - I am sure you have had several of these requests. Please let me know if there is a better person to contact.
Best
Ryan Hooper
Press Association
(44) 07794 047599
This email is from the PA Media Group. For more information, see www.pamediagroup.com. This email may
contain confidential information. Only the addressee is permitted to read, copy, distribute or otherwise use this
email or any attachments. If you have received it in error, please contact the sender immediately. Any opinion
expressed in this email is personal to the sender and may not reflect the opinion of the PA Media Group. Any
email reply to this address may be subject to interception or monitoring for operational reasons or for lawful
business practices.
EFTA00016957


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=== Page 1 ===
OUTSIDE FIELD REP Auto-
mative marketing CO. FT/PT
PERSON needed for answer-
ing phones & light cleaning
during School Holidays Call
Miss Maxwell,
PEST CONTROL TECH
No experience necessary.
Will train in all areas. Clean
driving & good health a must.
Starting $250 wilk Call For in-
terview,


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=== Page 1 ===
Materials Provided for Review:
Documents:
1. Summons and Complaint - CMA V. JE/SK (2.25.08)
2. First Amended Complaint - CMA V. JE/SK (2.9.09)
3. Affidavit of Dr. Hall (SDNY_GM_01986418)
3500 Materials:
3505-001
3505-005
3505-026
3505-027
3505-028
3505-030
3505-031
3505-034
3505-035
3505-036
3505-043
3505-044
3505-058
3505-059
3505-068
3505-074
3505-076
3505-079
3505-081
3505-088
3505-089
3505-090
3505-091
3505-092
3505-097
3505-100
1
EXHIBIT F
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=== Page 1 ===
Case 16-3945, Document 56, 07/18/2017, 2081160, Page1 of 1
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
New York, NY 10007
ROBERT A. KATZMANN
CHIEF JUDGE
CLERK OF COURT
Date: July 18, 2017
DC Docket #: 15-cv-7433
Docket #: 16-3945cv
DC Court: SDNY (NEW YORK
Short Title:
V. Maxwell
CITY)
DC Judge: Sweet
NOTICE OF CASE MANAGER CHANGE
The case manager assigned to this matter has been changed.
Inquiries regarding this case may be directed to
EFTA00014506


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Filing today
Date: Thu, 13 Aug 2020 20:42:22 +0000
No worries. Believe me, I sympathize. For what it's worth, I turned on "Wi-Fi Calling" in my Settings and it
made a huge difference.
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:41 PM
To:
(USANYS)
Subject: RE: Filing today
Ok. Sorry to miss the calls Have been working in basement for last couple hours where I get no cell service.
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:40 PM
To:
(USANYS)
Subject: RE: Filing today
I would have reached out to them directly if I didn't share the concern. With your confirmation as reinforcement,
I called her back and she completely agrees that
and
have got it covered.
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:36 PM
To:
(USANYS)
Subject: RE: Filing today
I didn't ask because I thought it was honestly heavy handed. You really think we should?
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:35 PM
To:
(USANYS)
Subject: RE: Filing today
just called (she'd tried you first since it was Maxwell). She'd like us (you and me) to have eyes on the
draft if possible before it's filed. Think you can swing that with
and
?
Original Message
From:
(USANYS)
Sent: Thursday, August 13, 2020 4:33 PM
To:
(USANYS)
;
(USANYS)
(USANYS)
Subject: FW: Filing today
FYI, BOP is not moving her to general population as requested in the motion, and our response will argue that
the court should defer to the BOP and its determination as to what is necessary, but the team has been working
EFTA00015893

=== Page 2 ===
with the BOP to increase her computer/discovery access, which was the principal way she argued she was being
impacted by her restrictive conditions.
Original Message
From:
(USANYS) [Contractor]
Sent: Thursday, August 13, 2020 4:29 PM
To:
(USANYS)
(USANYS)
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
(USANYS)
Subject: Filing today
I understand you're supposed to be filing a response today (by 5:00?) to a defense motion to have Maxwell
released to the general population at MDC, or at least to be detained under conditions they say would allow her
greater access to a computer and the opportunity to review discovery materials? Main (OPA) is keenly interested
because of the AG's response last summer to Epstein's suicide and his bow to overhaul BOP and ensure inmate
safety, so a guy down there asked if we could send him what you file as soon as you do. (Apparently the AG is
getting questions from Congressional Republicans about what's being done to ensure Maxwell's safety.)
Chief Public Information Officer
U.S. Attorney's Office, SDNY
(office)
(cell)
EFTA00015894


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=== Page 1 ===
Event: 10:00 Epstein meeting
Start Date: 2007-09-24 12:00:00 +0000
End Date: 2007-09-24 12:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2007-09-19 18:13:08 +0000
Date Modified: 2010-11-11 02:32:10 +0000
Priority: 5
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=== Page 1 ===
From:
To:
Ce:
Subject: SDNY Press Clippings, July 31, 2020
Date: Fri, 31 Jul 2020 16:43:22 +0000
Inline-Images: image001.png
OF JUSTICE
SDNY PRESS CLIPPINGS
THE
JUSTITIA
July 31, 2020
Maxwell
BBC: https://www.bbc.com/news/world-us-canada-53605784
CNN: https://www.cnn.com/videos/us/2020/07/31/ghislaine-maxwell-jeffrey-epstein
cannell-newday-vpx.con/video/playlists/new-day-highlights/
Mediaite: https://lawanderime.com/high-profile/heres-where-we-found-bill-clintons-name-in-newly-unsealed-jeffrey-epstein-court-documents/
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=== Page 1 ===
From:
To:
Cc:
Subject: Great St James Island
Date: Fri, 16 Aug 2019 14:14:19 +0000
Attachments: US_Virgin_Islands_Corporations_Subp_Rider_GREAT_ST_JIM_LLC.docx:
Deed_Great_St_Jim_LLC_2016000575.pdf;
Deed_Great_St_Jim_LLC_additional_Parcels_USVI_2016000576.pdf
Good morning
Attached is a subpoena rider for this Epstein entity (GREAT ST JIM LLC) which purchased parcels on Great St
James Island in January 2016.
Also attached are the two Deeds from the two conveyances.
Squad C-40 (FAST) Senior Financial Investigator (SFI)
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=== Page 1 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
V.
)
)
Case No.
)
)
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested) Ghislaine Maxwell
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
Date:
06/29/2020
Issuing officer's signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
Date:
Arresting officer's signature
Printed name and title
EFTA00016393


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=== Page 1 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
The information in this rap sheet is subject to the following caveats:
This record contains Florida information only. When explanation of a
charge or disposition is needed, communicate directly with the agency
that contributed the record information. (; 2021-10-06)
This record may only be used for the purpose requested as defined by
the Code of Federal Regulations and/or Florida Statute. (; 2021-10-06)
** Expunged pursuant to Florida Statute(s) 943.0515 ** (; 2021-10-06)
** Sealed pursuant to Florida Statute(s) 943.0595 ** (; 2021-10-06)
This is a single-source offender record. (; 2021-10-06)
IDENTIFICATION
1/10
EFTA00015140

=== Page 2 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
CRIMINAL HISTORY
2/10
EFTA00015141

=== Page 3 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
3/10
EFTA00015142

=== Page 4 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
4/10
EFTA00015143

=== Page 5 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
EFTA00015144

=== Page 6 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
6/10
EFTA00015145

=== Page 7 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
Severity Misdemeanor
Disposition (Guilty/Convicted 2012-01-18; Same)
0
EFTA00015146

=== Page 8 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
Prosecutor Disposition (Cycle 010)
Prosecutor Agency
8/10
EFTA00015147

=== Page 9 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
9/10
EFTA00015148

=== Page 10 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
INDEX OF AGENCIES
Agency
Palm Beach County Sheriffs Office; FL0500000;
Agency
Volusia County State Attorney's Office;
FL064015A;
Address
251 North Ridgewood Avenue
Daytona Beach, FL 32114
Agency
Daytona Beach Police Department; FL0640100;
Agency
Palm Beach County Clerk of Court; FL050015J;
Agency
Palm Beach County State Attorney's Office;
FL050015A;
Address
401 N. Dixie Hwy
West Palm Beach, FL 33401
Agency
Palm Beach Shores Police Department; FL0503300;
Address
247 Edwards Lane
Palm Beach Shores, FL 33404
Agency
North Palm Beach Police Department; FL0502300;
*** END OF RECORD ***
10/10
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=== Page 1 ===
Signature Page Summary
Angara Trust
Account Number and Description
Signature Requirement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
RMA Domestic - Trust
Client Relationship Agreement
de 0104 1386 2771 11/07/2016
Package ID: 0186545016
1
SDNY_GM_02742237
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=== Page 2 ===
Intentionally Left Blank
de 0104 1386 2772 11/07/2016
SDNY_GM_02742238
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=== Page 3 ===
Client Information
Client Information
Client Information
Angara Trust
Trust Information
U.S. Federal law requires us
Trust Type
Irrevocable Trust
to obtain, verify and record
information that identifies
Name
Angara Trust
each person or entity
Jurisdiction
US Trust
that opens an Account with
us. When you open an
Date Established
09/15/2016
Account, we will ask for
Name of All Trustees
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
We may also ask to see a
driver's license or other
documents that will allow
Name of All Grantors
us to identify you.
Ghislaine Maxwell
Please review and verify all
of the information that you
provided to us when you
Contact Information
opened your Account. If
Residential Address
you have changes,
corrections or additions,
City, State, Zip Code
Boston, MA 02210-2698
notify your Financial Advisor
as soon as possible.
Home Phone
E-mail Address
If you share assets with
another person, the net
worth figure here shows
your portion only, based
upon instructions you
Net Worth Information
provided
Annual Income
Investment Information:
This section reflects answers
Liquid Assets (cash and marketable securities)
you provided related to
your investment experience,
Net Worth (excluding primary residence)
market knowledge and
Federal Marginal Tax Rate
other assets and is used to
ensure our investment
recommendations are
suitable for your situation.
Investment Information
Years you have held investment accounts
Individual Stocks
Equities
Bonds
Futures
Options-Buy
Options-Sell
Knowledge of investments
Percentage of total investable assets held at UBS
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
3
3
SDNY_GM_02742239
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=== Page 4 ===
Account Information
Account Information
Account Information
Please review the information
about each of your accounts
and notify your Financial
Advisor immediately if you
have any changes or
corrections.
For more information, please
refer to the UBS Deposit
Account Sweep Program
Disclosure Statement
Please note the account risk
profile and investment
objective below are specific only
to this account other accounts
may have different account risk
profiles and investment
objectives.
Your Account Risk Profile for
this particular account is defined
as:
Aggressive Willing to accept
high risk to principal and high
volatility to seek high returns over
time.
Different accounts may have
different risk profiles
Your Investment Objective
Produce a Combination of
Income and Capital
Appreciation Investments
seeking both the generation of
income and growth of principal.
A senior political official is
defined as a President or Vice
President, Cabinet Member,
Supreme Court Justice,
member of the Joint Chief's
Staff, Member of Congress or
a Parliament, Chairperson,
Head or Senior Leader of a
major religious organization,
or the like.
4
4
SDNY_GM_02742240
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 14:29:31 +0000
Attachments: Maxwell - Dkt_No_348.pdf
Hi
Judge Nathan just ordered us to respond to this letter as soon as possible but no later than 5 pm today. We've reached
out to BOP to set up a call.
Thanks,
From:
(USANYS)
Sent: Thursday, October 14, 2021 8:31 PM
To:
(USANYS)
>;
(USANYS)
Cc:
is
is
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
FYI, letter filed by Bobbi Sternheim tonight.
From: BOBBI C STERNHEIM <bcsternheim@mac.com> >
Sent: Thursday, October 14, 2021 7:46 PM
To:
)
is
(USANYS)
is
is
)
Cc: Christian Everdell <CEverdell@CohenGresser.com; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main: 212-243-1100
Cell: 917-912-9698
EFTA00016723

=== Page 2 ===
Fax: 888-587-4737
bcsternheim@mac.com
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
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=== Page 1 ===
From:
)"
To: Christian Everdell
(USANYS)"
Cc: 'Jeff Pagliuca'
i
Laura Menninger
"Bobbi Sternheim
)"
Subject: RE: Discovery Issues
Date: Fri, 23 Apr 2021 16:30:15 +0000
Inline-Images: image001.jpg; image002.jpg
Chris,
Following up on these issues:
For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they
were not produced.
For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was
available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none
is viewable, except for data showing when a particular file was saved to a drive by the investigative team or
prepared for production. I am not aware of any additional metadata in our possession that you do not have for
these files.
For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came
from the CDs that your team reviewed last week. The available metadata for those photographs was produced in
two excel spreadsheets with the same production - one with metadata for nude images (which were contained on
one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were
produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am
working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows
in the spreadsheet.
For #6:
The SDNY_GM_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files
have the same metadata on the hard drive that was available when the FBI seized each file. For files that
were carved or deleted, no metadata was recovered, so none is viewable.
The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette
tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were
converted by our vendor.
The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's
residences, which you reviewed last week. As referenced above, those photographs were not processed by
CART, which is why they do not have a CART number. As referenced above, the available metadata for those
photographs was produced in two excel spreadsheets with the same production - one with metadata for
nude images (which were contained on one of the hard drives you reviewed last week), and one with
metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I
mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey
to you which Bates numbers correspond with which rows in the spreadsheet.
Best,
EFTA00015636

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, March 30, 2021 11:10 PM
To: Christian Everdell
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; ; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for
you on #3-#6.
Best,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Tuesday, March 30, 2021 10:58 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your
vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7.
As for #1 and #2, I will call
at MDC and represent to her that we have your concurrence to send the
drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she
refuses, we will take it up with Judge Nathan.
EFTA00015637

=== Page 3 ===
Thanks,
Chris
From:
) [mailto:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim (
)
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC
legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive
if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized
each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data
showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that were
the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I
have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that
was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the
SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019
searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so
they did not come from any of the electronic devices that were the subject of extractions by CART. As a result,
these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
EFTA00015638

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
EFTA00015639

=== Page 5 ===
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
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PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00015640


c1: EFTA00016342
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016342.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
(USANYS)"
Subject: FW: Amazon Ref. No. CRIM1071168 2020 DS In Re: Subpoena 20 Mag. 6216
Date: Sat, 27 Jun 2020 21:08:28 +0000
Attachments: CRIM1071168_2020_DS_Response_26June2020.xlsx
Will, could you please create a folder for this doc in the share for subpoena returns, and update our spreadsheet tracker?
Thank you!
From: Rodelo, Teresa
Sent: Friday, June 26, 2020 18:47
To
(NY) (FBI)
Cc:
(USANYS)
is
Subject: Amazon Ref. No. CRIM1071168 2020 DS In Re: Subpoena 20 Mag. 6216
Dear
Dear
Attached please find Amazon's response to the above-referenced request. For privacy and other legal reasons, we have
redacted the titles of expressive materials. Amazon reserves any and all objections that Amazon may have with respect to
this law enforcement request, including that the information and/or records requested are unusually voluminous in
nature and that compliance with such order otherwise would cause an undue burden on Amazon.
Sincerely,
Teresa Rodelo
Manager, Law Enforcement Response Team
Amazon.com, Inc.
2021 7th Avenue, Seattle, WA 98121
W:
e:
NOTICE: This communication might contain privileged and/or confidential information. If you are not the intended recipient or you believe that you have received this
communication in error, please delete this message and do not print, share, or otherwise use this message or its contents in any way. Please also indicate by reply email
that you have received this communication in error and that you have deleted it.
EFTA00016342


c1: EFTA00014417
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014417.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Final Voucher 11062816(1) approved by
,
now awaiting further approval
Date: Mon, 24 Feb 2020 21:39:58 +0000
Importance: Normal
Dear
Final voucher 11062816(1) has been approved by
, now awaiting further approval.
Trip ID: 11062816
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13401 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Pending Voucher Approval
Voucher total expenses: 1040.52
Estimated trip cost: 1368.26
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# V0010
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.
EFTA00014417


c1: EFTA00014658
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014658.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Start Date: 2021-11-21 19:00:00 +0000
End Date: 2021-11-21 19:30:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2021-11-20 22:01:13 +0000
Date Modified: 2021-11-20 22:01:13 +0000
Priority: 5
DTSTAMP: 2021-11-20 21:54:30 +0000
Attendee: Stoddart, Allison
EFTA00014658


c1: EFTA00016448
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016448.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Gloria Allred
Cc:
)"
Subject: Call today
Date: Thu, 21 May 2020 19:21:07 +0000
Gloria,
Would you be available for a quick call this afternoon? We have a couple quick questions for you relating to the Epstein
case. I'm available to talk any time.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016448


c1: EFTA00016607
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016607.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Meet on Epstein
Date: Tue, 17 Sep 2019 13:37:59 +0000
Importance: Normal
Attachments: unnamed
EFTA00016607


c1: EFTA00015712
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015712.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Jeffrey Epstein Moved Money Overseas in Transactions His Bank Flagged to U.S.
Date: Tue, 23 Jul 2019 22:22:17 +0000
Yep. Team was already on it. McFadden has discussed in her interview
Sent from my iPhone
> On Jul 23, 2019, at 6:18 PM,
wrote:
>
V
>
https://www.nytimes.com/2019/07/23/business/jeffrey-epstein-deutsche-bank.html
V
>
> Sent from my iPhone
EFTA00015712


c1: EFTA00016266
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016266.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
"
Subject: FW: U.S. V GHISLAINE, MAXWELL
Date: Mon, 01 Nov 2021 23:49:04 +0000
Attachments: LB1TMAXF.PDF
From: Goretti Moya <gmoya@sdreporters.com>
Sent: Monday, November 1, 2021 7:07 PM
To:
Subject: [EXTERNAL] U.S. V GHISLAINE, MAXWELL
EFTA00016266


c1: EFTA00014294
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014294.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Voucher for Trip 10643456-2 is late
Date: Thu, 03 Oct 2019 13:24:08 +0000
Good Morning! I just talked to
You have submitted the claim for reimbursement.
Nothing else you need to do. This is an automatically computer generated email. It is nothing we can do to stop
sending the auto emails.
I will address this issue to EOUSA if they can do something about it.
Thank you.
Original Message
From:
Sent: Thursday, October 03, 2019 5:50 AM
To:
Cc:
Subject: Re: Voucher for Trip 10643456-2 is late
I keep getting these emails. Do I need to submit anything else? Please advise - thanks.
Sent from my iPhone
V
On Oct 1, 2019, at 05:03, "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com> wrote:
>
> Dear
V
> Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
V
> Trip ID: 10643456-2
> Traveler name:
> Destination: Santa Monica
> Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews Trip
> Dates: 2019-09-17 - 2019-09-20 Current status: Authorization Approved
V
> 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
>
V
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
V
EFTA00014294

=== Page 2 ===
> 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# V0013
> 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.
EFTA00014295


c1: EFTA00015877
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015877.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Automatic reply: Jeffrey Epstein's final days at NYC jail revealed by inmates - New York Daily
News
Date: Mon, 28 Dec 2020 17:08:36 +0000
I will be on leave the week of December 28. I will be checking email regularly, but for matters requring
immediate attention, please contact
or call my cell,
EFTA00015877


c1: EFTA00016962
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016962.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Call from SDNY
Date: Wed, 17 Apr 2019 20:05:19 +0000
Importance: Normal
Thanks!
From:
Sent: Wednesday, April 17, 2019 10:25 AM
To:
Subject: FW: Call from SDNY
Hi
Here you go.
has been dealing with the First Assistant in MDFL,
Hope this is helpful.
From:
Sent: Wednesday, April 17, 2019 10:22 AM
To
Subject: RE: Call from SDNY
I last dealt with
in the Middle District of Florida. She is the First Assistant who would likely have the
authority to issue the letter authorizing SDNY access to grand jury materials our office developed.
From:
Sent: Wednesday, April 17, 2019 9:51 AM
To:
Subject: FW: Call from SDNY
Following up on this.
Thanks
From:
Sent: Friday, April 5, 2019 2:24 PM
EFTA00016962

=== Page 2 ===
To:
Subject: Call from SDNY
Just received a call from the Crim Chief in SDNY. SDNY has an open criminal matter involving Jeff
Epstein. They understand we are recused and have shared nothing about the matter. The
purpose of the call concerned their efforts to obtain from the FBI in the SDFL the evidence
gathered as part of the SDFL Epstein investigation. The Miami FBI has expressed a reluctance to
send any 6e materials to the SDNY FBI without a 6e letter. Given our recusal from the
underlying criminal matter, I don't believe we should be the ones to give the FBI the go-ahead
or the 6e letter. We no longer control that evidence.
Do you have the name and contact information for the new USAO/AUSA handling our old
criminal case? I think the best bet is to put SDNY in touch with that AUSA.
Thanks
EFTA00016963


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c0:
=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Sun, 28 Nov 2021 21:17:45 +0000
Thanks so much, Jake
From
Sent: Sunday, November 28, 2021 4:14 PM
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
This group certainly isn't scared. I know this has been a slog, but it's all really summed up below - there isn't a crime
much worse than this one, and it's hard to think of something more worthy of prosecution. Good luck tomorrow!!
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
EFTA00016510


c1: EFTA00014183
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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Telephone Conference re: Epstein
Start Date: 2008-12-03 19:00:00 +0000
End Date: 2008-12-03 19:30:00 +0000
Organizer:
Location: My office
Class: X-PERSONAL
Date Created: 2008-11-26 19:37:53 +0000
Date Modified: 2022-10-02 08:11:14 +0000
Priority: 5
DTSTAMP: 2008-11-26 19:32:25 +0000
Attendee:
When: Wednesday, December 03, 2008 2:00 PM-2:30 PM (GMT-05:00) Eastern Time (US &
Canada).
Where: My office
EFTA00014183


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Jeffrey EPSTEIN
Date: Thu, 25 Jul 2019 13:02:48 +0000
Thanks
Appreciate it.
From:
Sent: Thursday, July 25, 2019 6:00 AM
To:
Cc:
is
Subject: Re: Jeffrey EPSTEIN
I have requested a copy of the report prepared for the incident. I will forward it once I receive it.
On Jul 24, 2019, at 10:41 PM,
wrote:
Received, thanks for passing this on. Do you have any additional information or reports?
On Jul 24, 2019, at 9:35 PM,
wrote:
All,
Please be advised that we received the following report from the Bureau of Prisons MCC New York at 2115 hours on
this date:
Associate Warden (AW)
at MCC New York advised that Jeffrey EPSTEIN was found in his cell this
morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was
assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where
he currently remains. Additionally, AW
advised that EPSTEIN's cell mate reportedly threated to kill him.
No further information was provided.
The above incident is currently under investigation with the BOP.
Supervisory Deputy United States Marshal
Southern District of New York
EFTA00014624


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=== Page 1 ===
From: Jeffrey Epstein <jeevacation@gmail.com>
Date: 22 July 2009 at 05:27:50 GMT-7
free and home
EFTA00015064


c1: EFTA00016171
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016171.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Note to file - Call with Mike Monico
Date: Wed, 17 Jul 2019 20:18:47 +0000
Mike Monico and Barry Spevack called on behalf of Cohen. They asked whether we would file a Rule 35, and requested a
meeting to discuss it. I asked what had changed since we told them, on April 17, that we did not intend to file such a
motion. They said that Cohen "has heard Trump say things about Epstein," but would not get into detail at this time
about what those were. They then attempted to rehash our April 17 conversation about Rule 35, and asked for specifics
about what Cohen had done to undermine his credibility. I said I would consider whether we were willing to provide
more specifics.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
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=== Page 1 ===
From:
To:
Subject: filed letter
Date: Wed, 17 Jul 2019 20:46:46 +0000
Attachments: 2019-07-17_JE_detention_submission.Final.pdf
Here's the filed version.
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00016758


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=== Page 1 ===
From:
Date: Fri, 31 Jan 2020 02:39:08 +0000
https://foxwilmington.com/headlines/prince-andrew-must-cooperate-in-jeffrey-epstein-probe-give-up-ghislaine-
maxwell-royal-cousin-says/
EFTA00017040


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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
(USAFLS)"
(USAFLS)"
(USAFLS)"
Subject: RE: Jane Does V USA/Epstein
Date: Fri, 05 Dec 2008 23:31:18 +0000
Importance: Normal
I have not. Your draft supplemental declaration (Nov 18, 2008) is fine. If you would sign and scan it, I will file everything on Monday.
Thanks.
Original Message
From:
(USAFLS)
Sent: Friday, December 05, 2008 6:08 PM
To:
(USAFLS);
(USAFLS);
(USAFLS);
(USAFLS)
Subject: Jane Does V USA/Epstein
Hi all. Yet another of our favorite lawyers has filed the non-pros agrmt with the court. He filed it under seal and asked the court to unseal it.
- did you ever file the motn for summ judgment and my amended declaration?
I sent the notifications about the work release to all of the represented victims via their attorneys this afternoon.
EFTA00014155


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=== Page 1 ===
From:
To:
Subject: Voucher for Trip 10810414 is late
Date: Fri, 22 Nov 2019 05:05:17 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 10810414
Traveler name:
Destination: Santa Monica
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Trip Dates: 2019-11-13 - 2019-11-15
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# V0013
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.
EFTA00015715


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=== Page 1 ===
From:
)"
To: "Miller, Michael"
Martin Weinberg
"
,
Reid"
Marc Fernich
,
Cc:
)"
)"
Subject: Discovery production
Date: Tue, 30 Jul 2019 17:08:02 +0000
All,
Our first discovery production will include approximately 12 GB of data. As a result, we need to request that you please
provide us with a drive (or drives if you would like multiple copies) on which to load the discovery for you. You can either
bring the drive(s) to tomorrow's conference, or you can send them to our office at the below address to my attention.
Once we receive a drive (or drives) from you, we will get it loaded and sent back out to you as quickly as possible.
Additionally, if you would like Mr. Epstein to receive his own electronic copy of the discovery to review at the MCC, please
provide us with a hard drive (not a thumb drive-the MCC will only accept external hard drives) for us to load and send to
the MCC for his review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00014534


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=== Page 1 ===
PCS
PROFESSIONAL CHILDREN'S SCHOOL
Please include $40 non-refundable Application Fee. Admission IS not completed until the applicant has been accepted
by the School and an enrollment contract has been signed by both the parent and the school. All sections must be fully
completed (section J, if applicable). Please print or type.
Date 6/25/98
SECTION A.
1
SECTION B.
ALEXANDER w. DREYFOOS
Grades/dates attended
Reason for leaving
GOVERNMENT
EXHIBIT
761
S2 20 Cr. 330 (AJN)
PCS0000020
EFTA00016517

=== Page 2 ===
SECTION C.
SECTION D. Required for students who live away from home.
Guardian's name
Name of business
Guardian's address
Business address
Telephone (
)
Business telephone
(
)
Fax (
)
Relationship to student
Occupation/position
SECTION E.
Who has financial responsibility? Mr. Jeffrey Epstein
Address 457 Madison Ave.
City/state/zip New York, N.Y. 10022
Bank reference (name and branch) J.P. Morgan, 5th Ave.
Do you expect to apply for financial assistance? [
]
Yes
X
]
No
SECTION F. Other children in family
PCS0000021
EFTA00016518

=== Page 3 ===
SECTION G. Have you any relatives who attended PCS? No
Name
Relationship
Class (if known)
SECTION H. How did you become interested in PCS? (List name and address if applicable.)
SECTION I. Student History
Does the student have an illness or disability which would limit his/her school activities? [ ] Yes
X
] No
Please explain.
Has student's school attendance been interrupted for a period of a month or more due to medical reasons?
[ ] Yes
X
] No
Please give reasons and approximate dates.
circumstances.
Has the candidate ever attended summer school? [
]
Yes
X
No
Give the name and address of the school, the
subjects taken, and the reasons for attending.
Has the candidate had special tutoring? [ ]
Yes
X
No
Please indicate the subject(s), the grade(s), when the
candidate was tutored, and the circumstances.
Describe any special oircumstances which have affected the candidate's performance in school (for example, learning
disabilities, illness, physical handicaps, or frequent changes of home or schools). - NONE-
PCS0000022
EFTA00016519

=== Page 4 ===
SECTION J. If the student is "Professional" or "Pre-Professional," please fill out this section.
96
activities generally accorded or made available to students at the School. It does not discriminate on the basis of color, religion, sex or national and ethnic origia
in administration of its educational policles, scholarship and loan programs, or athictic and other school administered programs
Please mail this form to: Director of Admissions, Professional Children's School, 132 West 60th Street, New York, N.Y. 10023. Thank you.
PCS0000023
EFTA00016520


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 19 May 2020 14:09:23 +0000
Thanks very much. Let's wait until you have the full info from
From:
Sent: Monday, May 18, 2020 10:44 PM
To:
is
Cc:
in
Subject: FW: Epstein search warrant documents
We can send you one similar to the USVI one but we are waiting on some info from
in terms of
electronics processing clarification so were waiting for that before sending to you so it was a complete picture.
But if you are ok with just the device and location seizure info we can go ahead and send that for now.
Let us know your preference.
EFTA00016965


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=== Page 1 ===
Event: CEOS Meeting re Epstein Investigation
Start Date: 2009-12-17 18:00:00 +0000
End Date: 2009-12-17 19:30:00 +0000
Organizer:
Location: By Phone - Call-in #
Class: X-PERSONAL
Date Created: 2009-12-14 18:52:09 +0000
Date Modified: 2022-10-02 08:11:13 +0000
Priority: 5
DTSTAMP: 2009-12-14 21:34:04 +0000
Attendee:
EFTA00014184


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
Cc:
(NY) (FBI)"
i
Subject: RE: Ghislaine Maxwell Siblings
Date: Wed, 01 Jul 2020 19:45:09 +0000
No problem!
The only Marriage license for Scott Borgerson was on 5/19/2001 to Rebecca Piorunneck. Checks for Ghislaine Maxwell (in
every state) were negative.
From:
) [mailto:
Sent: Wednesday, July 01, 2020 3:29 PM
To:
(NY) (FBI)
Cc:
is
)
Subject: RE: Ghislaine Maxwell Siblings
Thanks very much! Somewhat related, are you able to determine whether Maxwell is married? And in particular whether
she is married to Scott Borgerson?
thanks,
From:
(NY) (FBI)
Sent: Wednesday, July 01, 2020 15:27
To:
Subject: FW: Ghislaine Maxwell Siblings
Good afternoon,
Below is information regarding Maxwell's siblings.
From:
(NY) (FBI)
Sent: Wednesday, July 01, 2020 2:55 PM
To:
,
(NY) (FBI)
is
Subject: Ghislaine Maxwell Siblings
1. Christine Maxwell
Address:
EFTA00017736

=== Page 2 ===
2. Isabel Maxwell
Address:
3. Karine Maxwell
DOB:
Deceased
4. Ann (Anne) Maxwell (Anne Holve)
DOB:
Married Lawrence Holve
No identified residence in US
i. OUTBOUND flight on 5/23/2015 to UK
5.
***Kevin Maxwell
DOB:
No identified residence in US
i. INBOUND flight on 2/29/2020 to Boston from London
6. Michael Maxwell
DOB:
Deceased
7. lan Maxwell
DOB:
No identified residence in US
i. OUTBOUND flight on 12/27/2017 to London from Boston
8. Philip Maxwell
DOB:
No travel history
No identified residence in US
Let me know if you need anything else!
EFTA00017737


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=== Page 1 ===
From:
To:
Subject: RE: Call
Date: Mon, 20 Sep 2021 18:59:52 +0000
Inline-Images: image001.jpg; image002.jpg; image005.jpg
What happened? Call just dropped for me.
From:
Sent: Monday, September 20, 2021 1:11 PM
To:
Subject: RE: Call
Can we do 1:30 pm today?
Special Agent
U.S. Department of Justice
Office of the Inspector General
New York Field Office
US
New York, NY 10004
SPECIAL
THE
From:
Sent: Monday, September 20, 2021 12:38 PM
To:
Subject: RE: Call
Hi - Want to talk today? When are you free?
From:
Sent: Thursday, September 16, 2021 9:15 AM
To:
Subject: Call
Good Morning
Please let me know if you have a few minutes to speak with myself and SSA
regarding the Epstein case.
Thank you.
Special Agent
U.S. Department of Justice
Office of the Inspector General
New York Field Office
US
New York, NY 10004
EFTA00017091


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=== Page 1 ===
Event: Call with FBI (Epstein)
Start Date: 2019-06-28 18:00:00 +0000
End Date: 2019-06-28 18:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2019-06-24 22:47:38 +0000
Date Modified: 2019-06-24 22:47:38 +0000
Priority: 5
DTSTAMP: 2019-06-24 22:35:37 +0000
Attendee:
(USANYS)
Alarm: Display the following message 15m before start
Reminder
EFTA00015526


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=== Page 1 ===
From:
"
"
To:
Cc: Andrew Tomback
Subject: RE: Epstein NY property
Date: Thu, 16 Jul 2020 14:26:46 +0000
Thanks
I'll send a dial-in for 1:30.
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor New York, NY 10004-1482
Offic
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Thursday, July 16, 2020 10:25 AM
To:
is
>;
Cc: Andrew Tomback
Subject: RE: Epstein NY property
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Any time in that range works for us - if you send a dial-in, we'll call whenever you set it for. Thanks, and speak with you
then.
From:
Sent: Thursday, July 16, 2020 10:04
To:
is
)
V.
Cc: Andrew Tomback
Subject: Epstein NY property
:
Would you have time for a call today for an update on the NY property? If so, would something between 1:00-1:45 work?
EFTA00015954

=== Page 2 ===
Thanks,
Marc
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York, NY 10004-1482
Office
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00015955


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Ghislaine Maxwell Siblings
Date: Wed, 01 Jul 2020 19:45:52 +0000
That is incredibly helpful, thanks very much.
From:
Sent: Wednesday, July 01, 2020 15:45
To:
Cc:
Subject: RE: Ghislaine Maxwell Siblings
No problem!
The only Marriage license for Scott Borgerson was on 5/19/2001 to Rebecca Piorunneck. Checks for Ghislaine Maxwell (in
every state) were negative.
From:
Sent: Wednesday, July 01, 2020 3:29 PM
To:
Cc:
Subject: RE: Ghislaine Maxwell Siblings
Thanks very much! Somewhat related, are you able to determine whether Maxwell is married? And in particular whether
she is married to Scott Borgerson?
thanks,
From:
Sent: Wednesday, July 01, 2020 15:27
To:
Subject: FW: Ghislaine Maxwell Siblings
Good afternoon,
Below is information regarding Maxwell's siblings.
EFTA00016394

=== Page 2 ===
From:
Sent: Wednesday, July 01, 2020 2:55 PM
To:
Subject: Ghislaine Maxwell Siblings
1. Christine Maxwell
2. Isabel Maxwell
3. Karine Maxwell
Deceased
4. Ann (Anne) Maxwell (Anne Holve)
Married Lawrence Holve
No identified residence in US
i. OUTBOUND flight on 5/23/2015 to UK
5.
***Kevin Maxwell
No identified residence in US
i. INBOUND flight on 2/29/2020 to Boston from London
6. Michael Maxwell
Deceased
7. lan Maxwell
No identified residence in US
i. OUTBOUND flight on 12/27/2017 to London from Boston
8. Philip Maxwell
No travel history
No identified residence in US
Let me know if you need anything else!
EFTA00016395


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=== Page 1 ===
I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin
Islands, declare this to be my last will and testament.
FIRST
I hereby revoke all my prior wills and codicils.
SECOND
I give all my property to the Trustees of The Jeffrey E. Epstein 2001 Trust
One created pursuant to an agreement dated November 8, 2001, by JEFFREY E.
EPSTEIN, as Grantor, and JEFFREY E. EPSTEIN and JEFFREY A. SCHANTZ, as
Trustees, to be added to the principal thereof and disposed of as provided thereunder.
THIRD
(a)
I appoint JEFFREY A. SCHANTZ and PAUL HOFFMAN as
Executors of this will.
(b)
I authorize JEFFREY A. SCHANTZ to designate one or more
additional or successor Executors. Designations shall be in writing and may be revoked
in writing by the maker thereof at any time prior to the qualification of the person so
designated. I authorize JEFFREY A. SCHANTZ to remove any Executor acting
hereunder by a written and acknowledged instrument.
(c)
Any reference in this will to my Executors shall include additional
and successor Executors.
(d)
No one acting hereunder as Executor shall be required to (i)
furnish any bond, undertaking or other security in any jurisdiction, (ii) file periodic
reports in or to any court or (iii) give notice of appointment as Trustee to any court. Each
Trustee acting hereunder is specifically relieved from any and all of the duties which
[00172266-1]
GJ_000103
EFTA00016841

=== Page 2 ===
would otherwise be placed upon him by Chapter 59 of Title 15 of the Virgin Islands
Code.
(e)
Each Executor acting hereunder shall be entitled to receive the sum
of One Hundred Thousand Dollars ($100,000) as compensation for such services.
FOURTH
Unless the context otherwise requires, the use in this will of the masculine
and feminine shall be interchangeable, and the use of the singular and plural shall be
interchangeable.
FIFTH
In extension and not in limitation of the powers and authority which my
Executors would otherwise have pursuant to law or pursuant to the other provisions of
this will, I direct that they have the following discretionary powers:
(a)
To retain for as long a period of time as they may consider
advisable or proper any property of any kind which may at any time be in their hands.
(b)
To sell at public or private sale or to exchange any property which
I may own at the time of my death or which may at any time be in their hands, without
application to court, on any terms they may consider advisable or proper, including terms
involving an extension of credit for any period of time and with or without security.
(c)
To invest in or otherwise acquire any property, real or personal, of
any kind, without limitation, without being bound by any provision of law restricting
investments by executors, including but not limited to common and preferred stocks,
secured and unsecured obligations, mutual and common funds, other securities,
mortgages, and interests and options in any of the foregoing.
2
GJ_000104
[00172266-1]
EFTA00016842

=== Page 3 ===
(d)
To acquire and retain property without regard to any principles of
diversification.
(e)
To permit funds to remain uninvested, and to retain for an
unlimited period of time and to acquire and retain property which is not productive of
income.
(f)
To acquire, exercise, sell or abandon conversion, subscription and
other rights and options, and to grant options for any period of time.
(g)
To hold securities in the names of nominees or in such form as to
pass by delivery.
(h)
To pay any gift or bequest in whole or in part at any time after my
death, either before or after the expiration of any period authorized or provided by law for
the payment of same and without deducting any discount or interest from a gift or
bequest paid prior to such time or paying interest on a gift or bequest paid after such time.
(i)
To employ attorneys, accountants, investment advisers, security
analysts, brokers, agents, clerks, bookkeepers, stenographers and assistants, and to pay on
a regular basis the fair and reasonable value of their services, and in connection with this
power an Executor who is an attorney, an accountant or a broker or any firm of attorneys,
accountants or brokers of which an Executor is a partner or employee may be retained on
behalf of my estate and compensated for services rendered.
(j)
To borrow money for any purpose, including, but not limited to,
the payment of taxes, and to pledge or mortgage property as security for money
borrowed.
[00172266-1]
3
GJ_000105
EFTA00016843

=== Page 4 ===
(k)
To lend money or other property to any person, corporation,
partnership, trust or other entity, including a beneficiary hereunder even if such
beneficiary is an Executor, this power to include the power to lend, without interest,
income to or for the benefit of principal and principal to or for the benefit of income.
(1)
To pay any gift or bequest and to distribute income or principal in
cash or in kind or partly in each. Such payments and distributions may be made to any
legatee or beneficiary with property that is like or different from property used to pay any
other gift or bequest or make any other distribution to any other legatee or beneficiary.
The value of any property distributed in kind shall not be reduced to reflect any expenses
or taxes that may be incurred by the recipient in or as a result of a disposition of such
property. The decision of my Executors with respect to the property selected to pay any
&
gift or bequest or make any distribution shall be conclusive and no recipient shall have
the right to object thereto.
(m) To determine, in case of reasonable doubt on their part, whether
any property coming into their hands constitutes income or principal, and whether any
payment or expenditure made by them shall be charged to income or to principal.
(n) To operate, repair, alter and improve any real property which they
may hold or in which they may hold an interest or participation; to erect or demolish
buildings thereon; to enter into leases for such real property or any part thereof or any
interest or participation therein for any period of time; to mortgage such real property or
any part thereof or any interest or participation therein for any period of time; to grant
options with respect to such real property, mortgages and leases or any interest or
participation therein for any period of time; to perform, modify, waive provisions of,
[00172266-1]
4
GJ_000106
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=== Page 5 ===
extend, renew, terminate or otherwise act in respect of any such leases, mortgages or
options; to cause such real property or any interest or participation therein or any part
thereof and themselves to be insured against any and all risks; to retain an agent or agents
for any of the foregoing purposes; to set up a reserve or reserves for depreciation and/or
obsolescence, and to do or omit to do anything of any kind or nature with respect to any
such real property or any part thereof or any interest or participation therein or any lease
or mortgage thereon or option with respect thereto and the management thereof which
they may in their discretion consider advisable, whether or not such act or omission is
hereinabove specifically mentioned, without being bound by restrictions which might
otherwise be applicable and without court approval.
(o)
To retain any interest in, to invest in and to become a member of,
any real estate partnership or joint venture, to comply with all the terms and provisions of
every real estate partnership and joint venture relating to any investment at any time held
by them, to succeed me as a member of any such partnership or joint venture, and to vote,
execute consents, exercise all rights and take such other action with respect to any real
estate partnership or joint venture as they, in their discretion, deem advisable.
(p)
To retain any interest in oil, gas or mineral leases; to contract to
make and make, execute and deliver oil, gas or mineral leases, on such terms and with
such reservations of royalties or interests as they may deem proper; to amend ratify and
confirm any and all oil, gas or mineral leases made by me or by them; to sell and convey
any interest in oil, gas or other minerals; and to execute division orders relating to any
such interest and to the oil, gas or other minerals produced therefrom.
GJ_000107
[00172266-1]
5
EFTA00016845

=== Page 6 ===
(q)
To become or continue to be an officer, director or employee of
any corporation, stock of which may be owned by my estate and as such officer, director
or employee to receive a salary, bonus or other compensation in reasonable amount for
services rendered to said corporation.
(r)
To determine whether to claim any deduction available to me or
my estate on estate tax or on income tax returns in such manner as they may deem
advisable and without making any adjustment between income and principal or among
beneficiaries on account of any such determination.
(s)
If more than one Executor is acting, to delegate to any one of my
Executors any nondiscretionary power, including but not limited to the power, singly or
with others, to sign checks, withdrawal slips, instructions for the receipt or delivery of
securities or other property, and instructions for the payment or receipt of money, and the
power, singly or with others, to have access to any safe deposit box or other place where
property of my estate is deposited.
(t)
To transfer any property which they may at any time hold to any
jurisdiction which they may deem advisable.
(u)
My Executors shall continue to have all the powers herein vested
in them until the final distribution of all property in their hands.
SIXTH
If any beneficiary under The Jeffrey E. Epstein 2001 Trust One ("the
trust") shall in any way directly or indirectly (a) contest or object to the probate of my
will or to the validity of any disposition or provision of my will or of the trust or (b)
institute or prosecute, or be in any way directly or indirectly instrumental in the
institution or prosecution of, any action, proceeding, contest, objection or claim for the
[00172266-1]
6
GJ_000108
EFTA00016846

=== Page 7 ===
purpose of setting aside or invalidating my will or the trust or any disposition therein or
provision thereof, then I direct that (a) any and all provisions in the trust for such
beneficiary and his issue in any degree shall be null and void and (b) my estate, whether
passing under my will or the trust or pursuant to the laws of intestacy, shall be disposed
of as if such beneficiary and his issue in any degree had all failed to survive me.
IN WITNESS WHEREOF, I have hereunto subscribed my name and
affixed my seal to this my Last Will and Testament, consisting of 8 typewritten
pages, on all of which I signed my name for greater security and identification, at
St. homes
, U.S. Virgin
Islands on the 11th day of December, 2001.
(L.S.)
JEFFREY EPSTEIN
SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and
for his Last Will and Testament in our presence; and we thereupon, at his request and in
his presence, and in the presence of each other, have hereunto subscribed our names as
attesting witnesses and our respective places of residence on the day of its execution.
CRdeL
residing at
st. Thomas, VI
Juanne Bunnan residing at
St. Thomas, VI
Dephne Psyden residing at
St. Thomas, VI
[00172266-1]
7
GJ_000109
EFTA00016847

=== Page 8 ===
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN,
Testator, and Cecile R. desongh , Jeanne Brennan
and
Daphne Blyden
, "witnesses, the 11th day of December, 2001.
Before me, the undersigned authority, on this day personally appeared JEFFREY E.
EPSTEIN, Testator, and Cecile R.de Jongh Jeanne Brennan
and
Daphne Blyden , respectively, whose names are subscribed to the
foregoing instrument in their respective capacities, and all of said persons being by me
duly sworn, the said Testator declared to me and to the said witnesses, in my presence,
that the said instrument is his LAST WILL AND TESTAMENT and that he has willingly
made and executed it as his free act and deed for the purposes therein expressed; and that
the said witnesses, each on his oath, stated to me in the presence and hearing of said
Testator that the said Testator had declared to them that the said instrument is his LAST
WILL AND TESTAMENT, and that he executed the same as such and wanted each of
them to sign it as a witness; and upon their oaths, each witness further stated that they did
sign the same as witnesses in the presence of the said Testator and at his request; and that
said Testator was at the time eighteen years of age or over and of sound mind; and that
each of said witnesses was then at least eighteen years of age.
Testator
N
CRdLZ
Jeanne Bunnon
Wapime Psyden
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EVSTEIN,
Testator, and Cecile R. de Jongh , Jeanne Brennan
and
Daphne Blyden
, witnesses, the 11th day of December, 2001.
Barbara Mignon Weatherly
Notary Public
Barbara Mignon Weatherly
Notary Commission No. LNP-027-00
Commission Expires November 21, 2004
[00172266-1]
8
GJ_000110
EFTA00016848

=== Page 9 ===
FIRST CODICIL
to
LAST WILL AND TESTAMENT
of
JEFFREY E. EPSTEIN
GJ_000111
EFTA00016849

=== Page 10 ===
I, JEFFREY E. EPSTEIN, of Little St. James Island, United
States Virgin Islands, having made my last will and testament dated
December 11, 2001, declare this to be a first codicil thereto.
FIRST
I hereby delete Article THIRD of my will and substitute in its
place the following new Article THIRD:
"(a) I appoint HENRY JARECKI and JAMES CAYNE as
Executors of this will. If either HENRY JARECKI or JAMES CAYNE fails
to qualify or ceases for any reason to act as Executor, I hereby designate
PAUL HOFFMAN as successor Executor to act in his place.
(b) Any reference in this will to my Executors shall include
successor Executors.
(c) No one acting as Executor shall be required to (i) furnish
any bond, undertaking or other security in any jurisdiction, (ii) file periodic
reports in or to any court or (iii) give notice of appointment as Trustee to any
court. Each Trustee acting hereunder is specifically relieved from any and
all of the duties which would otherwise be placed upon him by Chapter 59
of Title 15 of the Virgin Islands Code.
(d) Each Executor acting hereunder shall be entitled to
receive the sum of One Hundred Thousand Dollars ($100,000) as
compensation for such services."
316766.1
GJ_000112
EFTA00016850

=== Page 11 ===
SECOND
In all other respects I ratify and republish my said last will and
testament.
IN WITNESS WHEREOF, I have hereunto subscribed my
name and affixed my seal to this my first codicil to my Last Will and
Testament, consisting of 2 typewritten pages, on all of which I signed
my name for greater security and identification, at
U.S. Virgin Islands on the 27 day of June , 2003.
JEFFREY
S E. EPSTEIN (L.S.)
SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E.
EPSTEIN, as and for a first codicil to his Last Will and Testament in our
presence; and we thereupon, at his request and in his presence, and in the
presence of each other, have hereunto subscribed our names as attesting
witnesses and our respective places of residence on the day of its execution.
DAPHNE WALLACE
Waphne Wallace
ST. THOMAS, VI 00802
from RUAN A.R
ST. Thomas USVI
Jonne Bunnon
St. Thomas USVI
316766.1
2
GJ_000113
EFTA00016851

=== Page 12 ===
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and DAPHNE WALLACE, Jeanne Brennan
2003. and JERMANE A. RUAN , witnesses, the 273 day of June
,
Before me, the undersigned authority, on this day personally appeared
JEFFREY E. EPSTEIN, Testator, and DAPHNE WALLACE ,
JERMAINE A. RUAN and Jeanne Brennan
,
respectively, whose names are subscribed to the foregoing instrument in
their respective capacities, and all of said persons being by me duly sworn,
the said Testator declared to me and to the said witnesses, in my presence,
that the said instrument is a first codicil to his LAST WILL AND
TESTAMENT and that he has willingly made and executed it as his free act
and deed for the purposes therein expressed; and that the said witnesses,
each on his oath, stated to me in the presence and hearing of said Testator
that the said Testator had declared to them that the said instrument is a first
codicil to his LAST WILL AND TESTAMENT, and that he executed the
same as such and wanted each of them to sign it as a witness; and upon their
oaths, each witness further stated that they did sign the same as witnesses in
the presence of the said Testator and at his request; and that said Testator
was at the time eighteen years of age or over and of sound mind; and that
each of said witnesses was then at least eighteen years of age.
Testator
N
Waphne Wallace
formina A. Rue
Junne Burnor
316766.1
3
GJ_000114
EFTA00016852

=== Page 13 ===
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and Daphne Wallace, Jermaine A. Ruan,
and Jeanne Brennan, witnesses, the 27th day of June , 2003.
Barbara MignonWeaths
Notary Public
Notary Commission No. LNP-027-00
Barbara Mignon Weatherly
Commission Expires November 21, 2004
316766.1
4
GJ_000115
EFTA00016853

=== Page 14 ===
I, JEFFREY E. EPSTEIN, of Little St. James Island, United
States Virgin Islands, having made my last will and testament dated
December 11, 2001 and a first codicil thereto dated June 27, 2003, declare
this to be a second codicil thereto.
FIRST
I hereby delete paragraph (a) of Article THIRD of my will and
substitute in its place the following new paragraph (a) of Article THIRD:
"I appoint HENRY JARECKI, JAMES CAYNE and
LAWRENCE NEWMAN as Executors of this will. If HENRY JARECKI,
JAMES CAYNE or LAWRENCE NEWMAN fails to qualify or ceases for
any reason to act as Executor, I hereby designate PAUL HOFFMAN as
successor Executor to act in his place."
SECOND
In all other respects I ratify and republish my said last will and
testament and the first codicil thereto.
IN WITNESS WHEREOF, I have hereunto subscribed my
name to this my second codicil to my Last Will and Testament on the 3rd day
of December , 2004.
JEFFREY V E. EPSTEIN
(L.S.)
358376.1
GJ_000116
EFTA00016854

=== Page 15 ===
SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E.
EPSTEIN, as and for a second codicil to his Last Will and Testament in our
presence; and we thereupon, at his request and in his presence, and in the
presence of each other, have hereunto subscribed our names as attesting
witnesses and our respective places of residence on the day of its execution.
Darren K. life
Livingston, NJ 07039
Lawrence revemen
Sands Point, N.Y. nesc
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN
and
, witnesses, the 3rd day of December
,
2004.
GOD Notary Public
LAUREN J. KWINTNER
Notary Public, State of New York
No. 02KW6016686
Qualified in New York County
Commission Expires November 30, 2006 06
358376.1
GJ_000117
EFTA00016855

=== Page 16 ===
Before me, the undersigned authority, on this day personally appeared
JEFFREY E. EPSTEIN, Testator, and DARREN K. INDYKE
and
LAWRENCE NEWMAN and
,
respectively, whose names are subscribed to the foregoing instrument in
their respective capacities, and all of said persons being by me duly sworn,
the said Testator declared to me and to the said witnesses, in my presence,
that the said instrument is a second codicil to his Last Will and Testament
and that he has willingly made and executed it as his free act and deed for
the purposes therein expressed; and that the said witnesses, each on his oath,
stated to me in the presence and hearing of said Testator that the said
Testator had declared to them that the said instrument is a second codicil to
his Last Will and Testament, and that he executed the same as such and
wanted each of them to sign it as a witness; and upon their oaths, each
witness further stated that they did sign the same as witnesses in the
presence of the said Testator and at his request; and that said Testator was at
the time eighteen years of age or over and of sound mind; and that each of
said witnesses was then at least eighteen years of age.
Testator
Lawsine Kewme
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN
and
, witnesses, the 3rd day of December
,
2004.
Good Notary Public
LAUREN J. KWINTNER
358376.1
Notary Public, State of New York
No. 02KW6016686
Qualified in New York County,
Commission Expires November 30,20 000118
EFTA00016856

=== Page 17 ===
I, JEFFREY E. EPSTEIN, of Little St. James Island, United
States Virgin Islands, having made my last will and testament dated
December 11, 2001, a first codicil thereto dated June 27, 2003, and a second
codicil thereto dated December 3, 2004, declare this to be a third codicil
thereto.
FIRST
I hereby delete paragraph (a) of Article THIRD of my will and
substitute in its place the following new paragraph (a) of Article THIRD:
"I appoint HENRY JARECKI, JAMES CAYNE and.
LAWRENCE NEWMAN as Executors of this will. If HENRY JARECKI,
JAMES CAYNE or LAWRENCE NEWMAN fails to qualify or ceases for
any reason to act as Executor, I hereby designate DARREN K. INDYKE as
successor Executor to act in his place."
SECOND
I hereby delete paragraph (d) of Article THIRD of my will and
substitute in its place the following new paragraph (d) of Article THIRD:
"(d) Each Executor acting hereunder shall be entitled to receive
the sum of Two Hundred Fifty Thousand Dollars ($250,000) as
compensation for such services."
360075.1
GJ_000119
EFTA00016857

=== Page 18 ===
THIRD
In all other respects I ratify and republish my said last will and
testament and the first codicil and second codicils thereto.
IN WITNESS WHEREOF, I have hereunto subscribed my
name to this my third codicil to my Last Will and Testament on the 16th day
of December , 2004.
V JEFFREY E. EPSTEIN
(L.S.)
SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E.
EPSTEIN, as and for a third codicil to his Last Will and Testament in our
presence; and we thereupon, at his request and in his presence, and in the
presence of each other, have hereunto subscribed our names as attesting
witnesses and our respective places of residence on the day of its execution.
Livingston, NJ 07039
Lawrence newman
sands Poent, N.Y. 11050
360075.1
2
GJ_000120
EFTA00016858

=== Page 19 ===
Before me, the undersigned authority, on this day personally appeared
JEFFREY E. EPSTEIN, Testator, DARREN K. INDYKE
and
LAWRENCE NEWHAN , respectively, whose names are subscribed to
the foregoing instrument in their respective capacities, and all of said
persons being by me duly sworn, the said Testator declared to me and to the
said witnesses, in my presence, that the said instrument is a third codicil to
his Last Will and Testament and that he has willingly made and executed it
as his free act and deed for the purposes therein expressed; and that the said
witnesses, each on his oath, stated to me in the presence and hearing of said
Testator that the said Testator had declared to them that the said instrument
is a third codicil to his Last Will and Testament, and that he executed the
same as such and wanted each of them to sign it as a witness; and upon their
oaths, each witness further stated that they did sign the same as witnesses in
the presence of the said Testator and at his request; and that said Testator
was at the time eighteen years of age or over and of sound mind; and that
each of said witnesses was then at least eighteen years of age.
Testator
K
Danen
Lawrence newman
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and Darrenk Indyke and Lawrence Newman,
witnesses, the 16 day of December 2004.
Notary GS Public
Notary Public, State of New York
LAUREN J. KWINTNER
No. 02KW6016686
Commission Expires November 30, 20 06
Qualified in New York County
360075.1
GJ_000121
EFTA00016859

=== Page 20 ===
Third Codicil to
EFTA00016860
Last Will
GJ_000122
Testament
JEFFREY E. EPSTEIN
LAWRENCE NEWMAN, Esq.
NEW YORK, NY 10019-6708
TELEPHONE

=== Page 21 ===
I, JEFFREY E. EPSTEIN, of Little St. James Island, United
States Virgin Islands, having made my last will and testament dated
December 11, 2001, a first codicil thereto dated June 27, 2003, a second
codicil thereto dated December 3, 2004, a third codicil thereto dated
December 16, 2004, and a fourth codicil thereto dated September 5, 2007,
declare this to be a fifth codicil thereto.
FIRST
I hereby delete paragraphs (b) (c) and (d) of Article THIRD of
my will and substitute in its place the following new paragraphs (b) (c) and
(d) of Article THIRD:
"(b) Any reference in this will to my Executors shall include
additional and successor Executors.
(c) No one acting hereunder as Executor shall be required to
(i) furnish any bond, undertaking or other security in any jurisdiction, (ii)
file periodic reports in or to any court or (iii) give notice of appointment as
Trustee to any court. Each Trustee acting hereunder is specifically relieved
from any and all of the duties which would otherwise be placed upon him by
Chapter 59 of Title 15 of the Virgin Islands Code.
509420.1
GJ_000123
EFTA00016861

=== Page 22 ===
(d) Each Executor acting hereunder shall be entitled to
receive the sum of Five Hundred Thousand Dollars ($500,000) as
compensation for such services."
SECOND
In all other respects I ratify and republish my said last will and
testament and the first codicil, second, third and fourth codicils thereto.
IN WITNESS WHEREOF, I have hereunto subscribed my
name to this my fifth codicil to my Last Will and Testament on the 20th day of sept.
, 2007.
JEFFREY D E. EPSTEIN
(L.S.)
SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E.
EPSTEIN, as and for a fifth codicil to his Last Will and Testament in our
presence; and we thereupon, at his request and in his presence, and in the
presence of each other, have hereunto subscribed our names as attesting
witnesses and our respective places of residence on the day of its execution.
Daven K.OShe
Livingston, NJ 07039
Lawrence newman
Sando Point, N.Y. 11050
509420.1
2
GJ_000124
EFTA00016862

=== Page 23 ===
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN,
witnesses, the 20th day of September, 2007.
12 Notary Public, State of New York
Notary Public
LAUREN J. KWINTNER
No. 02KW6016686
Qualified in New York County
Commission Expires November 30, 20 10
509420.1
3
GJ_000125
EFTA00016863

=== Page 24 ===
STATE OF NEW YORK
COUNTY OF NEW YORK
Before me, the undersigned authority, on this day personally appeared
JEFFREY E. EPSTEIN, Testator, DARREN K. INDYKE and
LAWRENCE NEWMAN , respectively, whose names are subscribed to
the foregoing instrument in their respective capacities, and all of said
persons being by me duly sworn, the said Testator declared to me and to the
said witnesses, in my presence, that the said instrument is a fourth codicil to
his Last Will and Testament and that he has willingly made and executed it
as his free act and deed for the purposes therein expressed; and that the said
witnesses, each on his oath, stated to me in the presence and hearing of said
Testator that the said Testator had declared to them that the said instrument
is a fourth codicil to his Last Will and Testament, and that he executed the
same as such and wanted each of them to sign it as a witness; and upon their
oaths, each witness further stated that they did sign the same as witnesses in
the presence of the said Testator and at his request; and that said Testator
was at the time eighteen years of age or over and of sound mind; and that
each of said witnesses was then at least eighteen years of age.
Testator
Lawrence newman
SUBSCRIBED AND SWORN TO before me by the said JEFFREY E.
EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN,
witnesses, the 20th day of september 2007.
Notary Public
2 Notary Public, State of New York
LAUREN J. KWINTNER
No. 02KW6016686
Qualified in New York County
509420.1
Commission Expires November 30, 20
GJ_000126
EFTA00016864


c1: EFTA00015631
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015631.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Deutsche!
Date: Thu, 11 Jul 2019 01:50:31 +0000
Importance: Normal
Did I call it or did I call it
https://www.nytimes.com/2019/07/10/business/jeffrey-epstein-net-worth.html
Assistant U.S. Attorney
Southern District of New York
EFTA00015631


c1: EFTA00016345
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016345.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Gorenstein NYSD Chambers
Cc:
)"
,
)"
Subject: RE: Application for Search Warrant
Date: Fri, 26 Jun 2020 01:48:19 +0000
Attachments: 1)_Application_&_Affidavit_for_SW_for_all_JE_electronic_devices.pdf
Thank you very much. Attached please find a revised affidavit correcting the error that Judge Gorenstein identified.
I will call the number provided at 9:10am tomorrow with the agent on the line.
Respectfully,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gorenstein NYSD Chambers
Sent: Thursday, June 25, 2020 7:43 PM
To:
)
Cc:
is
Subject: Re: Application for Search Warrant
Judge Gorenstein has reviewed the warrant materials. Please call him at
with your agent on the
line at 9:10 a.m. If there is no answer, please leave a callback number by voicemail or text and the Judge will
respond to you shortly thereafter. If you need a different call-in time, please let us know. Additionally, Judge
Gorenstein notes the following: "While it does not affect probable cause, the warrant application in paragraph
4 and Attachment A refers to Epstein being arrested on July 6, "2020." The AUSA may wish to send a new
application that provides a correct date."
From:
Sent: Thursday, June 25, 2020 4:58 PM
To: Gorenstein NYSD Chambers
Cc:
is
Subject: Application for Search Warrant
EFTA00016345

=== Page 2 ===
Good afternoon,
Attached for Judge Gorenstein's review please find an application for a search warrant, as well as a proposed warrant.
The agent is available to swear out this warrant tomorrow morning whenever would be convenient for the Court. I can be
reached on my cellphone at 347-344-8771.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016346


c1: EFTA00016919
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016919.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Fri, 07 Feb 2020 16:24:45 +0000
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
>;
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
)
i
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
)
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection with
the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by (copied here)? I've
left the hard drive with the materials on your chair. (And if we could please get that hard drive back once the materials
are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also be coming
shortly.)
EFTA00016919

=== Page 2 ===
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
EFTA00016920


c1: EFTA00015135
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015135.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
CWT
SatoTravel
Your Itinerary
Trip on Aug 26, 2019
Locator: HVDEOP
Date: Aug 23, 2019
Traveler
USA
ALL MCO+S MUST BE MAILED TO.
EOUSA
THIS IS YOUR OFFICIAL RECEIPT FOR TRAVEL
PLEASE RETAIN FOR VOUCHERING OR
REIMBURSEMENT PURPOSES.
Customer Number
643SR7F
Agent
3R
*TICKET PURCHASE WITH
FEES TOTALING 37.63PP CHARGED IN ADDITION TO TKT PRICE
FEE-USD37.63PP-AIR DOMESTIC, TRADITIONAL
Monday, August 26, 2019
Confirmation MMRMJA
Flight JETBLUE AIRWAYS 424
DEPARTURE
ARRIVAL
LOS ANGELES,CA
NEW YORK JFK, NY
11:17 AM, Aug 26, 2019
8:05 PM, Aug 26, 2019
Status
Confirmed
Class
Coach Class Y
Duration
05:48 (Non-stop)
Equipment
32S
Meal Service
Snack
Notes
DEP-TERMINAL 5
ARR-TERMINAL 5
CABIN-ECONOMY
SEAT ASSIGNMENT RESTRICTED TO AIRPORT CHECK-IN
Tuesday, August 27, 2019
Confirmation MMRMJA
X
Flight JETBLUE AIRWAYS 1623
DEPARTURE
ARRIVAL
NEW YORK JFK, NY
LOS ANGELES,CA
7:30 PM, Aug 27, 2019
11:04 PM, Aug 27, 2019
Status
Confirmed
Class
Coach Class - Z
Duration
06:34 (Non-stop)
Equipment
32S
Meal Service
Snack
Reserved Seats
22C (Aisle)
Notes
DEP-TERMINAL 5
ARR-TERMINAL 5
CABIN-ECONOMY
Name
Invoice / Ticket / Date
Base
Tax 1
Tax 2
Tax 3
Total
2706478/000SFCTRF/23AUG19
37.63
37.63
706478/2797393007028/23AUG19
USD 393.49
29.51US
8.40ZP
20.20XT
451.60
EFTA00015135

=== Page 2 ===
Total Amount
489.23
Form of Payment: CAXXXXXXXXXXXX8394
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OF THE NORTHERN MARIANA ISLANDS-CNMI, WITHOUT
TOUCHING AT A FOREIGN PORT OR PLACE, ARE NOT REQUIRED
TO PRESENT A VALID U.S. PASSPORT OR U.S. GREEN CARD.
HOWEVER, IT IS RECOMMENDED THAT TRAVELERS BRING A
GOVERNMENT ISSUED PHOTO ID AND COPY OF BIRTH
CERTIFICATE.
PLEASE VISIT WWW.CARLSONWAGONLIT.COM/AIRLINEBAGGAGEFEES
FOR BAGGAGE FEE INFORMATION. CHECK OPERATING CARRIER
FOR ALLOWANCE IF TRAVELING ON CODE SHARE FLIGHT.
CWTSATOTRAVEL CAN BOOK YOUR HOTEL ACCOMODATIONS. WE CAN ASSIST IN KEEPING COSTS
WITHIN PER DIEM AT A FEMA APPROVED PROPERTY, GUARANTEE YOUR RESERVATION FOR
LATE ARRIVAL, AND EVEN CHECK FOR A ROOM AT YOUR FAVORITE HOTEL AT LOW FEDROOM
OR CWTSATOTRAVEL GOVERNMENT RATES. ALL YOUR RESERVATIONS INCLUDED ON ONE
ITINERARY--AIR, CAR, AND HOTEL.
THANKS FROM YOUR CWTSATOTRAVEL TEAM!!!
EFTA00015136


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=== Page 1 ===
From:
To:
Subject: Celebrate Epstein team
Date: Sun, 28 Jun 2020 13:58:39 +0000
I thought we should set aside time after the team gets the indictment-the way we gather a team into
office for a
pat on the back after a victory.
A virtual pat on the back. Via WEBEX
I want to say:
Congratulations. Great job,
This was a challenging case to make - to say the least.
The facts were old and there was that pesky thing called a statute of limitations.
You worked your way through that to a solution that should win the day,
You had the challenge of working with victim witnesses whose cooperation and trust you needed to secure.
You did that with empathy and genuine caring about them and at the same time a dedication to bringing the case against
Maxwell that is indisputably a worthy case that should have been brought.
Your legal work was excellent as evidenced by your brilliant pros memos and well drafted indictment.
So I thank you and commend each of you individually and as a team.
If I could pass around a celebratory drink I would but instead I will simply ask you to raise a glass tonight with your
significant other and know that I am also raising one at home for you at the same time.
COMMENTS?
EFTA00015692


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Meeting
Date: Mon, 06 Jan 2020 16:10:30 +0000
Importance: Normal
Attachments: unnamed
EFTA00016756


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=== Page 1 ===
From:
To:
Subject: Fwd: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Date: Tue, 23 Mar 2021 20:42:24 +0000
Attachments: SDNY_US_v_Epstein.pdf;
35058_GSA_S36_USAO_SDNY_Epstein_Scanning_Submission.xlsx
Inline-Images: image001.png
I have
and
going ahead with this. It will be in place if Florida breaks down. If Florida comes
through, we just cancel it. CACI understands.
Sent from my iPad
Begin forwarded message:
From:
Date: March 23, 2021 at 4:40:09 PM EDT
To:
Cc:
Subject: Fwd: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Please go ahead with this. Time sensitive.
,
I suggest using AFF for now.
Sent from my iPad
Begin forwarded message:
From:
Date: March 23, 2021 at 3:56:48 PM EDT
To:
Cc:
,
Subject: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Hello
I hope this email finds you well and that you are having a wonderful Tuesday.
EFTA00015643

=== Page 2 ===
In response to the Request for Proposal, attached is CACI's proposal information for your review and
consideration.
Please let me know if you have any questions
Respectfully,
I
Contracts Administration
-
CACI INC. - Federal
Shared Services Center
7725 West Reno Ave.
Oklahoma City, OK 73127
Cell Phone: 540-553-6268
Office Phone:
Email:
This electronic message contains information from CACI International Inc or subsidiary companies, which may be company sensitive, proprietary, privileged or
otherwise protected from disclosure. The information is intended to be used solely by the recipient(s) named above. If you are not an intended recipient, be
aware that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in error,
please notify us immediately at postmaster@caci.com. With the exception of messages sent by authorized CACI contracts or purchasing personnel, nothing in
this message may be interpreted as a digital or electronic signature that can be used to: (a) authenticate either the submission or the acceptance of a proposal
or offer to contract, or (b) modify an existing contract.
CACI
EVER VIGILANT
EFTA00015644


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
)"
)"
)"
Subject: Epstein Op Meeting with FBI
Date: Thu, 27 Jun 2019 17:39:04 +0000
Importance: Normal
Attachments: unnamed
EFTA00014462


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=== Page 1 ===
From:
To:
Subject: Please email me your airfare & hotel itin today. Thanks
Date: Tue, 09 Jul 2019 23:38:50 +0000
Importance: Normal
Traveler,
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%20Library/TravelStateTaxExemption.pdf&action=default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
From:
Sent: Tuesday, July 09, 2019 2:09 PM
To:
is
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
is
EFTA00015585

=== Page 2 ===
Cc:
Subject: RE: travel approval request
Approved for the travel and necessary conference room.
Thank you for correctly setting your priorities.
From:
Sent: Tuesday, July 09, 2019 2:00 PM
To:
is
Cc:
Subject: RE: travel approval request
Hi
In connection with the Epstein case (2018R01618), we would like to request permission to travel this week for victim
interviews in Palm Beach, Florida. Our agents will be there starting tomorrow, through Sunday, and our current plan is for
some combination of our team
(
and me) to be there from Thursday** through Sunday. And also same as
last time, we'd like to ask permission to reserve a conference room at the hotel for those four days.
Thanks very much,
***we would never miss the BBQ.
From:
Sent: Wednesday, June 12, 2019 3:28 PM
To:
Cc:
is
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
EFTA00015586

=== Page 3 ===
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
EFTA00015587

=== Page 4 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00015588


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=== Page 1 ===
From:
To:
Subject: Fwd: Premises SW
Date: Thu, 02 Jul 2020 10:58:18 +0000
Attachments: SDNY_Premises_Search_Warrant_Bundle_(revised).pdf; ATT00001.htm
See attached. The subject premises is defined as 156 acres.
Begin forwarded message:
From:
Date: July 2, 2020 at 6:54:50 AM EDT
To:
Subject: Fwd: Premises SW
Not going through on my laptop so trying from my phone. It's paragraph 15. Paragraph 3 defines the subject
premises
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: July 2, 2020 at 6:21:58 AM EDT
To:
Subject: Premises SW
EFTA00017738


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=== Page 1 ===
Event: Accepted: Call with FBI (Epstein)
Start Date: 2019-06-28 18:00:00 +0000
End Date: 2019-06-28 18:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Comment:
Date Created: 2019-06-24 22:47:46 +0000
Date Modified: 2019-06-24 22:47:46 +0000
Priority: 5
DTSTAMP: 2019-06-24 22:36:47 +0000
EFTA00015528


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=== Page 1 ===
From:
To:
$
Cc:
Subject: Maxwell response re 17(c) subpoena
Date: Tue, 23 Nov 2021 00:27:09 +0000
Attachments: 2021.11.22_JSP_Letter_Response_to_Motions_to_Quash_to_MV-2_Redacted.pdf
Attached is Maxwell's response to the motions to quash her Rule 17 subpoena.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00014709


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=== Page 1 ===
1
j7v2espC kjc
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
UNITED STATES OF AMERICA,
New York, N.Y.
4
V.
19 Cr. 490 (RMB)
5
JEFFREY EPSTEIN,
6
Defendant.
7
X
Conference
8
July 31, 2019
11:05 a.m.
9
10
Before:
11
HON. RICHARD M. BERMAN,
12
District Judge
13
14
APPEARANCES
15
GEOFFREY S. BERMAN
16
United States Attorney for the
Southern District of New York
17
BY:
18
Assistant United States Attorneys
19
20
MARTIN G. WEINBERG
Attorney for Defendant
21
22
STEPTOE & JOHNSON, LLP
Attorneys for Defendant
23
BY: MICHAEL C. MILLER
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014546

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2
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1
THE COURT: So, today's conference was scheduled at
2
the end of the July 18 court conference hearing on that date.
3
I thought that we would devote at least the -- well, probably
4
most of today's proceeding to talking about the schedule in
5
this case, and I asked the lawyers to get together and see if
6
they could come up with a mutually agreeable schedule, which
7
would include trial date, motion practice, discovery, etc.
8
Does anybody want to let me know how you made out?
9
: Yes, your Honor.
10
We have conferred with defense counsel and talked
11
about a proposed schedule for this case. So we are prepared to
12
propose to the court today a schedule for discovery, for
13
discovery-related motions, for pretrial motions, and we are
14
also prepared to talk about setting a possible trial date.
15
THE COURT: Okay. What have you got in mind?
16
: So, with respect to discovery, we would
17
propose a discovery deadline of October 31 to complete
18
discovery, with one exception. There are materials from
19
devices seized from the defendant's residence in New York, and
20
the F.B.I. is beginning the process of reviewing that data.
21
In discussing that with defense counsel, we have begun
22
to discuss a process for a privilege-review protocol. It's
23
possible that process may take longer than October 31. But
24
aside from that universe of documents, we would propose setting
25
a schedule of October 31 as a deadline for discovery.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014547

=== Page 3 ===
3
j7v2espC kjc
1
For discovery-related motions, we would propose that
2
the defense file any motions that they are aware of relating to
3
discovery, to include motions relating to the nonprosecution
4
agreement, by September 13 --
5
THE COURT: By when?
6
:
September 13, your Honor.
7
--- that the government be permitted to respond by
8
October 4; with any reply due on October 11, as necessary.
9
Of course we understand that if the defense comes to
10
have additional motions related to discovery based on the
11
ongoing discovery process that we will confer and propose an
12
additional briefing schedule beyond that, as necessary. But
13
with respect to motions that the defense is already aware of,
14
including the NPA, that is the schedule that we would propose
15
at this time.
16
Regarding pretrial motions, your Honor, we would
17
propose that the defense file their motions by January 10, that
18
the government be permitted to respond by February 10, and that
19
any replies be due on or before February 24.
20
THE COURT: Got it.
21
: And finally, your Honor, we are prepared to
22
discuss a trial date in this case. The government is asking
23
the court to set a trial date in this matter. We would propose
24
that the court schedule this matter for trial in June of next
25
year, and we estimate that the trial would take approximately
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014548

=== Page 4 ===
4
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1
four to six weeks, and so that trial date would carry into
2
July. And I understand that the defense has some comments
3
about that proposal, but that's the government's proposal with
4
respect to a trial date.
5
THE COURT: Okay. Let me hear from the defense.
6
Do I understand it correctly that, with the exception
7
of the trial date, those dates are agreeable?
8
MR. WEINBERG: Those dates are agreeable, your Honor.
9
THE COURT: Counsel, whatever you wish to add, that
10
would be fine.
11
MR. WEINBERG: We would ask the court to set a
12
preliminary trial date immediately after Labor Day. I say
13
preliminary because we want time to assess Mr. Epstein's --
14
THE COURT: This year?
15
MR. WEINBERG: Yes.
16
THE COURT: This Labor Day. Okay.
17
MR. WEINBERG: We want time to assess Mr. Epstein's
18
ability to
19
(Counsel confer)
20
MR. WEINBERG: I'm sorry. I am being told that your
21
Honor was inquiring as to the year. Let me --
22
THE COURT: Yes. I thought you wanted a speedy trial,
23
and so --
24
MR. WEINBERG: Not with a four- to six-week trial with
25
discovery coming in October, Judge. I apologize for being
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014549

=== Page 5 ===
5
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1
imprecise. Labor Day 2020 or immediately thereafter. And I
2
make that recommendation -- we haven't received the discovery
3
yet. Understandably, it is coming, and I'm not in any way
4
contesting that there has been a delay, but we haven't had an
5
opportunity to start reviewing what the government has
6
predicted to be over a million pages of discovery with
7
Mr. Epstein and to assess Mr. Epstein's ability to exercise his
8
constitutional right, while at MCC, in assisting counsel
9
prepare for a very difficult case that addresses events that it
10
is alleged occurred 14 to 17 years ago.
11
THE COURT: Okay.
12
MR. WEINBERG: So, we need time to receive a million
13
pages of discovery and to prepare to defend a four- to six-week
14
trial, when a lot of the immediate attention is going to be on
15
the very unique and complex constitutional issues connected to
16
the nonprosecution agreement, our contention that the
17
government's allegations are inextricably intertwined and
18
constitutionally barred by the NPA. There are double jeopardy
19
issues both connected to the conspiracy count, which looks to
20
be an overlap with one of the charges that was expressly within
21
the immunity provisions in the NPA. We are going to be
22
spending a lot of time, and that's why I agreed with the
23
government that we should make early discovery motions on the
24
NPA-related issues, on double-jeopardy-related issues, so that
25
we could not only facially brief the motion to dismiss, but
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014550

=== Page 6 ===
6
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1
have the discovery, the subfacial discovery, if you will, so
2
that we could make a comprehensive briefing along the lines of
3
the schedule for motions.
4
THE COURT: That's what I was going to suggest, if
5
there is a time period when you could put it all together, as
6
it were, and there is a lot of flexibility. So I will leave
7
these dates, you know, for now.
8
With respect to the trial date, I could accommodate
9
either June or September of 2020. The issue is not so much as,
10
from my point of view, when you are all ready, but what part of
11
the calendar I block out. So is it realistic to block out time
12
in June?
13
MR. WEINBERG: I think it is -- I don't want to have
14
the court block out a six-week time and then come to the court
15
in March and say we need a continuance and risk a September
16
date.
17
THE COURT: Got it. Okay. So a September date, you
18
are saying, sounds like it certainly is realistic.
19
MR. WEINBERG: Thirteen months sounds like the amount
20
of time that we would ordinarily need to prepare a case of this
21
magnitude and scope.
22
THE COURT: All right. That is fine for me.
23
Just while we are taking care of details, a speedy
24
trial issue or application? Why don't we extend it to
25
September of 2020?
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014551

=== Page 7 ===
7
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1
MR. WEINBERG: This case certainly meets all of the
2
statutory criteria for complexity and we would agree to that
3
extension, Judge.
4
:
Your Honor, may I briefly be heard with
5
respect to the trial date?
6
THE COURT: Oh, sure. You know, it does sound like it
7
is kind of premature, but I'm happy to hear you. It is often
8
the defense that is ahead of the government, or not often, but
9
equally, but here it is the other way around. So if the
10
defense is not ready, it would be my practice to defer to the
11
defense, but I don't know that it is fixed in stone either way.
12
But, sure, I am happy to hear you.
13
:
Your Honor, by way of background, we had
14
initially proposed to the defense a May trial date. We think
15
that there is a public interest in bringing this case to trial
16
as swiftly as manageable. We understand, given their concerns
17
in wanting to have more time, we proposed a date in June as a
18
compromise position. We understand if the defense has
19
indicated that they need additional time. We are sensitive to
20
those concerns. But we do have a concern about the notion of
21
setting a September trial date and that that trial would be
22
preliminary or as a placeholder. Thirteen months is a
23
considerable amount of time for a case of this nature to go to
24
trial; and, again, given the time period of the charged conduct
25
and the length of time that's passed, we do think that there is
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014552

=== Page 8 ===
8
j7v2espC kjc
1
a public interest in scheduling a fixed trial date in this
2
case. Of course we understand if issues arise in the interim,
3
we will address that as it occurs, but we do think it makes
4
sense at this juncture to set a firm trial date. We don't
5
think that any delay in this case is in the public interest.
6
THE COURT: Counsel.
7
MR. WEINBERG: We think that the delay in bringing
8
this charge, your Honor, the natural corollary of that is to
9
make it more difficult, not easier, for us to defend
10
Mr. Epstein. For instance, there are certain sealed files for
11
potential witnesses that we would have to go to other courts to
12
seek to unseal. There is an NPA to litigate. This case is not
13
your ordinary 1591 case. A case of four to six weeks is not
14
the ordinary amount of time the government takes to prosecute,
15
whether it is old or new cases. We need 13 months. I'm trying
16
to make a principled argument, Judge, that that would be a
17
schedule that we would try our best to meet, conditioned on our
18
ability to work with Mr. Epstein under the current conditions.
19
Thank you, sir.
20
THE COURT: Okay.
21
So, we are going to monitor the case from now until
22
then anyway, so I think everybody will be in a better position
23
to know what is realistic with respect to a trial date. I will
24
exclude time from today through, let's say, June 8, but that,
25
of course, is without prejudice to hearing from the defense and
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014553

=== Page 9 ===
9
j7v2espC kjc
1
the government as to actually where things stand. Long before
2
then we will know. So we will have a conference, or several,
3
between now and then. Let's see where everybody is as the
4
months go by, and then we will know when we can effectively
5
hold the trial.
6
So I am going to find, under 18 United States Code $
7
3161, that the request for adjournment, joined in by both
8
sides, is appropriate and warrants exclusion of the adjourned
9
time from Speedy Trial calculations. I further find that the
10
exclusion is designed to prevent any possible miscarriage of
11
justice, to facilitate these proceedings, including extensive
12
pretrial preparation, and to guarantee effective representation
13
of and preparation by counsel for both sides, and thus the need
14
for exclusion and the ends of justice outweigh the interests of
15
the public and the defendant in a speedy trial pursuant to 18
16
United States Code § 3161 (h) (7) (A) and (B). So that exclusion
17
goes to June 8, 2020 preliminarily.
18
Counsel, is it your thought that these motions would
19
be on submission or did you want to have oral argument with
20
respect to any aspect of them?
21
MR. WEINBERG: We would seek oral argument, your
22
Honor.
23
THE COURT: So let's set October 28, 2019 for oral
24
argument, and I am tentatively reserving some time on my
25
calendar, as I said before, on June 8, 2020, but I will have a
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014554

=== Page 10 ===
10
j7v2espC kjc
1
much better feel for where things are long before that and
2
certainly I would say on October 28 we would have a much
3
clearer picture of how things stand.
4
So there you have it. Did you have -- go ahead.
5
: Just to clarify, your Honor, what time would
6
the court like the parties to appear on October 28?
7
THE COURT: 10 a.m.
8
: Thank you, your Honor.
9
THE COURT: And the June 8 date is 9 a.m. Okay?
10
MR. WEINBERG: Would your Honor want to schedule an
11
argument on the substantive motions that will be fully briefed
12
before the court on February 24?
13
THE COURT: Yup.
14
So let's schedule that oral argument for March 12,
15
2020, at 10 a.m.
16
Great. So anything anybody else has to talk about?
17
MR. WEINBERG: Not from the defense, your Honor.
18
: Not from the government, your Honor. Thank
19
you.
20
THE COURT: Okay.
21
MR. WEINBERG: Thank you very much, sir.
22
THE COURT: Nice to see you all.
23
o0o
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00014555


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
)"
Cc:
Subject: news article
Date: Tue, 16 Jul 2019 19:25:59 +0000
https://www.cbsnews.com/news/jeffrey-epstein-accuser-speaks-today-livestream-2019-07-16/
EFTA00014597


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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
("Cl ent") and his attorney,
Esq., with Assistant United States Attorney
0 be held by video conference
at the Office of the United States Attorney for the Southern Distri t of New York on October 7,
2020 ("the meeting"), the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMEN Γ. The Client has agreed to
provide the Government with information, and to respond to ques tions, so that the Government
may evaluate Client's information and responses in making prose utive decisions. By receiving
Client's proffer, the Government does not agree to make a motion 01 the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or on-prosecution agreement. The
Government makes no representation about the likelihood that any : uch agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, my statements made by Client
at the meeting, except (a) in a prosecution for false statements, ol struction of justice or perjury
with respect to any acts committed or statements made during or fter the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining eads to other evidence, which
evidence may be used in any prosecution of Client by the Gover ment; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements ma de by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client including arguments made or
issues raised sua sponte by the District Court) at any stage of the c iminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought gainst Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Se ction 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any stateme it made by Client during the
meeting, and all evidence obtained directly or indirectly therefro m, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this / greement to offer in evidence
any statements made by Client or leads obtained therefrom, Client hall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal R1 les of Evidence, or any other
federal rule that such statements or any leads therefrom should be uppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
01.14.2019
EFTA00015011

=== Page 2 ===
(6) If this Office receives a request from another pros ecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do so only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 al ove extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully d scussed and understand every
paragraph and clause in this Agreement and the consequences there of.
Dated: New York, New York
AUDREY STI AUSS
Acting United States Attorney for the
Southern Distr ct of New York
by
756
Dates of Continuation
Initials of cour sel. Client, AUSA, witness
11/12/2020
01.14.2019
EFTA00015012


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=== Page 1 ===
From:
To:
Subject: RE: Arlan Ettinger
Date: Wed, 09 Oct 2019 19:57:27 +0000
Agreed
From:
Sent: Wednesday, October 09, 2019 3:09 PM
To:
Subject: RE: Arlan Ettinger
I thought so too.
Would you please?
Many thanks.
From:
Sent: Wednesday, October 9, 2019 2:19 PM
To:
Subject: RE: Arlan Ettinger
A little cheeky, no? We get things like that when it looks like we'll have a monitor. I'll check with the team if
they anticipate us ever having anything to do with Epstein's property but I think the response (which could come
from me) will be something like, "Thank you for your letter, which has been forwarded to our Office for
response. We will file it in the event we have any occasion to follow up on your offer of services."
From:
Sent: Wednesday, October 9, 2019 2:06 PM
To:
Subject: FW: Arlan Ettinger
What is the right way to handle this? It seems to be an offer by Guernsey's Auctioneers & Brokers to be retained to handle
the disposition of Epstein's property. I was assigned to respond to this. Please advise.
Thanks
From:
)
Sent: Wednesday, October 9, 2019 1:57 PM
To:
Subject: Arlan Ettinger
Good afternoon!
I have been advised to forward you the attached correspondence from Arlan Ettinger, President of Guernsey's Auctioneers
& Brokers. The letter is regarding the property of the late Jeffrey Epstein. As advised by Nathaniel Gamble Il from ODAG
(see email attached), this has been assigned to USAO-SDNY for handling. Please let me know if you have any questions or
concerns.
EFTA00015288

=== Page 2 ===
Thank you very much in advance.
Best,
U.S. Department of Justice
Executive Office for U.S. Attorneys
0:
Pronouns: she/ her/ hers
EFTA00015289


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(NY) (FBI)"
Subject: Re: Jeffrey Epstein 19 cr 490
Date: Mon, 12 Aug 2019 19:06:30 +0000
Give me a call whenever you get a chance. Nothing urgent. Geoff
On Aug 12, 2019, at 12:57 PM,
(NY) (FBI)
wrote:
For info on attached.
Forwarded message
From:
(USMS)"
Date: Aug 12, 2019 12:55
Subject: FW: Jeffrey Epstein 19 cr 490
To:
(NY) (FBI)"
Cc:
FYI
United States Marshal
Southern District of New York
New York, NY 10007
Office -
Fax -
Original Message
From:
I mailto:
On Behalf Of
Sent: Monday, August 12, 2019 12:47 PM
To
Cc:
Greço,
(USMS)
i
)
Subject: Jeffrey Epstein 19 cr 490
Importance: High
Please see attached letter from Judge Richard M. Berman.
(See attached file: Aug 12 letter.pdf)
<Aug 12 letter.pdf>
EFTA00015301


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 25 Filed 07/15/20 Page 1 of SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 7/15/2020
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
At yesterday's proceeding, the Court set the following schedule for this matter:
Initial non-electronic discovery, generally to include search warrant applications
and subpoena returns, is due by Friday, August 21, 2020
Completion of discovery, to include electronic materials, is due by Monday,
November 9, 2020
Motions are due by Monday, December 21, 2020
Motion responses are due by Friday, January 22, 2021
Motion replies are due by Friday, February 5, 2021
Trial is set for Monday, July 12, 2021
so ORDERED.
Dated: July 15, 2020
New York, New York
Alim N.N.tto
ALISON J. NATHAN
United States District Judge
EFTA00014590


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Fwd: Preservation request
Date: Thu, 25 Jul 2019 17:03:27 +0000
Done.
Special Investigative Technician
MCC New York
New York, NY 10007
>>>
7/25/2019 12:18 PM >>>
Please the below, please preserve the video footage of the SHU tier containing cell Z06-215 from 11 pm July 22, 2019, until 4
am July 23, 2019. Please provide a copy for the investigation and maintain a copy in the event we are ordered to produce it
to the Court and counsel. Please advise when this has been done. Thank you.
Metropolitan Correctional Center
New York, New York 10007
>>>
7/25/2019 11:54 AM >>>
Hello
It was good to see you yesterday. Thank you for accommodating my visit with Tartaglione and giving him extra time to
review his discovery. We very much appreciate that.
I am writing to request the preservation of all video surveillance that captures the hallway outside of Tartaglione's cell on
the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July 23
during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23 at 4 am
is preserved. If it is your understanding that the incident occurred at a different time, please let me know and preserve the
relevant footage, including an hour before the incident and an hour afterwards. If the responding officers were wearing
body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that such footage also be
preserved.
We will be officially requesting this material through the appropriate means, but please consider this email a formal
preservation request.
Thank you.
EFTA00016910

=== Page 2 ===
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please
notify us immediately by telephone or email and immediately delete this message and all its attachments.
EFTA00016911


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=== Page 1 ===
From:
)"
To: Gary Bloxsome
Cc:
)"
)"
>, Daniel Cundy
"Jennifer
Richardson"
Subject: RE: U.S. Department of Justice investigation
Date: Mon, 27 Jan 2020 22:58:46 +0000
Inline-Images: image001.jpg; image002.jpg
Gary,
Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that
suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact provided
cooperation with our investigation. That is, he corrected the record generally in a factually accurate statement; I don't
believe this would create a misleading impression. I appreciate that you have advised us that your client has a desire to
cooperate, and we look forward to hearing from you when he has made a determination as to whether he is in fact willing
to speak with us.
Regards,
From: Gary Bloxsome
Sent: Monday, January 27, 2020 13:44
To:
Cc:
;
)
; Daniel Cundy ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York has
disclosed what we understood were confidential communications between us and
and
It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the
Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate with the
ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to do so.
We are concerned about the misleading impression that has been created and the effect this has on our ability to advise
the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any further public
statements on this topic.
Thank you.
Gary Bloxsome
Gary Bloxsome I
Partner
RANKED IN
Chambers
UK
500
MINGDOM
2020
TOP TIER
Leading Firm
2020
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00017743

=== Page 2 ===
On 22 Jan 2020, at 17:34,
wrote:
External email: is it safe to open attachments and links?
Gary,
We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 22, 2020 11:35
To:
Cc:
is
>; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome a
real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to gather
information from the Royal Household and others.
Best
Gary Bloxsome
Partner
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 20 Jan 2020, at 18:52,
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your response. It would be useful for us if you were able to help us understand the nature of the issues
and procedures with which you are dealing, particularly as it sounds like it will take at least a couple additional weeks
to address even minor preliminary issues, which suggests likely additional subsequent time to handle further
processes-and without a response to the question of whether he is willing to speak with us, separate from a general
desire to cooperate. Our investigation is moving forward expeditiously and so we would be grateful for some
understanding of the relevant issues (especially, though not exclusively, to the extent we may be able to assist in their
resolution) and would be happy to speak via phone if a real-time conversation would be more conducive to that
discussion.
thank you,
From: Gary Bloxsome
Sent: Monday, January 20, 2020 11:23
To:
EFTA00017744

=== Page 3 ===
Cc:
is
>; Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully with
the ongoing investigation by the DOJ.
It is our responsibility to deal with the various issues and procedures that arise here that will need to be addressed to
enable him to do so. We should be able to deal with at least some of the minor preliminary issues in the next two
weeks and we will update you on our progress once we have done so.
Regards,
Gary
Gary Bloxsome I Partner
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 18 Jan 2020, at 01:06,
wrote:
External email: is it safe to open attachments and links?
Gary,
We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in
particular the initial question, separate from any logistics, of whether you expect your client will be willing to speak
with us? And of course please let us know if any additional information would be useful to you.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 08, 2020 07:38
To:
Cc:
is
>; Daniel Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Friday 10th January at 1400(LDN) time is fine.
Please forward dial in details.
Kind regards
Gary
EFTA00017745

=== Page 4 ===
Gary Bloxsome I Partner
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 7 Jan 2020, at 18:56,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at
9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your
office line unless you'd prefer we use another number or a conference line.
thank you,
From: Gary Bloxsome
Sent: Tuesday, January 07, 2020 11:20
To:
Cc:
is
>; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome I Partner
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
EFTA00017746

=== Page 5 ===
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Jan 2020, at 01:38,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to
request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to
inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain
allegations that have arisen publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law
enforcement channels, we understand we may also alternatively inquire directly with counsel, when an individual
has legal representation. Given your representation, we are inquiring directly with counsel in the first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were
seeking as a threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
Cc:
is
>; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome I Partner
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
EFTA00017747

=== Page 6 ===
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
)
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of
Justice, Southern District of New York. We have been advised that you currently represent HRH The Duke of
York. Could you please advise whether that is correct? We - my colleagues
and I -
can be reached anytime at these email addresses, or please let us know if you would prefer to set up a time to
discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
EFTA00017748


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=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Mon, 03 Feb 2020 18:33:06 +0000
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just let
me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch base
midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right now
it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
EFTA00016834

=== Page 2 ===
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if that's
easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00016835


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=== Page 1 ===
Event: Epstein Trust Discussion
Start Date: 2020-07-06 17:15:00 +0000
End Date: 2020-07-06 18:00:00 +0000
Organizer:
Location:
Class: X-PERSONAL
Date Created: 2020-07-02 14:21:53 +0000
Date Modified: 2020-07-02 14:21:53 +0000
Priority: 5
DTSTAMP: 2020-07-02 13:48:18 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
-- Do not delete or change any of the following text. --
When it's time, join your Webex meeting here.
Meeting number (access code):
Meeting password:
Join meeting
EFTA00015695

=== Page 2 ===
Tap to join from a mobile device (attendees only)
1995719104## USA Toll 2
1995719104## US Toll
Join by phone
USA Toll 2
US Toll
Global call-in numbers
Join from a video system or application
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You can also dial
and enter your meeting number.
Join using Microsoft Lync or Microsoft Skype for Business
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Need help? Go to http://help.webex.com
EFTA00015696


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Subject: FW: victim travel
Date: Thu, 07 Oct 2021 16:48:00 +0000
Attachments: HVDEOP.pdf
Embedded: RE:_E-TICKET_RECEIPT
- Travel Date: 26AUG19 -
Ref: XHKCBU_.msg
From:
(USANYS)
Sent: Thursday, October 7, 2021 12:42 PM
To:
(USANYS)
is
(USANYS)
Subject: RE: victim travel
Hi
-
I have nothing under the name
in 2019. I only found airfare in 2019 that I charged to the GTA for
Thank you!
From:
(USANYS)
Sent: Thursday, October 7, 2021 9:29 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: Fwd: victim travel
Anything with this case was handled securely.
is on Maternity leave, but maybe she will be able to weigh in on this for you.
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: October 7, 2021 at 9:26:33 AM EDT
To:
(USANYS)"
Subject: FW: victim travel
Judge Berman had a heading in Epstein all the travel was paid for by SDNY in August 2019 can you look to see if we paid
for
and
Thanks,
EFTA00015132

=== Page 2 ===
From:
Sent: Wednesday, October 6, 2021 10:44 PM
To:
(USANYS)
Cc:
(USANYS)
is
Subject: victim travel
Hi
As we're preparing our disclosures, we wanted to check with you about two things:
Did SDNY pay for flights for
for the August 2019 hearing? What about the hotel?
Did SDNY pay for any travel related expenses for
for the August 2019 hearing? What about
the hotel?
When
travelled here in September 2021, our understanding is that the office paid for her flights.
Did the office pay for her hotel? We recall some correspondence about her booking her own hotel but wanted to
confirm.
Thanks!
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
"
(USANYS)"
Cc: "
(USANYS)"
Subject: RE: Epstein
Date: Fri, 03 Jan 2020 22:35:08 +0000
The murder mystery solved!
From:
(USANYS)
Sent: Friday, January 03, 2020 5:21 PM
To:
USANYS)
Cc:
(USANYS)
is
>;
>;
is
(USANYS) [Contractor]
Subject: Re: Epstein
It's on the death - there is a promo on their website.
Sent from my iPhone
On Jan 3, 2020, at 5:09 PM,
(USANYS)
wrote:
FWIW - we've heard that 60 Minutes might run a feature on Epstein this Sunday night. The info came from a different
outlet, so no details as of yet, but will let you know if we get anything further.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 497 Filed 11/23/21 Page 1 of 11
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/23/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As discussed at today's conference, attached is the Court's draft preliminary instructions
for the sworn jury. The Court has considered both parties' proposed instructions as to the
Court's order that certain witnesses be permitted to testify or be referred to by first name only or
pseudonym. Dkt. No. 432. The draft preliminary instructions include a limiting instruction
regarding this process.
The parties may suggest any proposed edits to the preliminary instructions by letter on or
before November 27, 2021, or they shall indicate by that date that they have no objections or
suggestions.
so ORDERED.
Dated: November 23, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
1
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20cr330, United States V. Maxwell
DRAFT - November 23, 2021
1
Preliminary Instructions to the Sworn Jury
2
Order of Trial
3
Now that you have been sworn, let me give you some instructions about
4
your duties as jurors. At the end of the trial I will give you more detailed
5
instructions, and those instructions will control your deliberations in this case. But
6
for now, let me explain how the trial will proceed.
7
The first step in the trial will be opening statements. The government will
8
make an opening statement. After that, I expect the lawyers for the defendant to
9
make an opening statement as well. Those statements are not evidence. They
10
serve no purpose other than to give you an idea in advance of the evidence that the
11
lawyers expect you to hear from the witnesses. Those statements permit the
12
lawyers to tell you a little bit of what the case is all about, but the only evidence
13
comes from the witnesses and the exhibits.
14
After opening statements, the government will present its evidence. The
15
government's evidence will consist of the testimony of witnesses as well as
16
documents and exhibits. The government will examine the witnesses, and then the
17
defendant's lawyers may cross-examine them. Following the government's case,
18
the defendant may present a case if she wishes. Again, because of the presumption
19
of innocence, the defendant is not required to offer any proof. If the defendant
1
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Case 1:20-cr-00330-AJN Document 497 Filed 11/23/21 Page 3 of 11
1
does present a defense case, the defense witnesses will testify, and the government
2
will have the opportunity to cross-examine them.
3
After the presentation of evidence is completed, the parties will deliver their
4
closing arguments to summarize and interpret the evidence. Just as the parties'
5
opening statements are not evidence, their closing arguments are not evidence
6
either.
7
Following closing arguments, I will instruct you on the law. Then, you will
8
retire to deliberate on your verdict, which must be unanimous and must be based
9
on the evidence or lack of evidence presented at trial. Your deliberations are
10
secret. You will never have to explain your verdict to anyone.
11
As I've told you, under the law, a defendant in a criminal case is presumed
12
innocent and cannot be found guilty of the crimes charged unless a jury, after
13
having heard all of the evidence in the case, unanimously decides that the evidence
14
proves the defendant guilty beyond a reasonable doubt.
15
In a criminal case the burden of proof remains with the prosecution - the
16
government. For the jury to return a verdict of guilty as to the defendant, the
17
government must prove that the defendant is guilty beyond a reasonable doubt. A
18
person charged with a crime has absolutely no burden to prove that she is not
19
guilty, and if the defendant chooses not to present any proof, that decision cannot
20
be held against her and may not enter into your deliberations at all. I will,
2
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1
however, instruct you fully on the burden of proof after all of the evidence has
2
been received.
3
4
The Judge's and Jury's Role
5
Now, let me explain the jobs that you and I are to perform during the trial. I
6
will decide which rules of law apply to this case. I will decide that by making
7
legal rulings during the presentation of the evidence, and also - as I told you - in
8
giving the final instructions to you after the evidence and arguments are completed.
9
In order to do my job, I may have to interrupt the proceedings from time to
10
time to confer with the parties about the rules of law that should apply here.
11
Sometimes we will talk here, at the bench, outside of your hearing. But some of
12
these conferences may take more time than others, so, as a convenience to you, I
13
may excuse you from the courtroom. I will try to avoid such interruptions as much
14
as possible, but please be patient and understand that these conferences are
15
necessary to ensure the fairness of the trial and often make the trial go faster.
16
While I decide the law that applies to this case, you, ladies and gentlemen of
17
the jury, are the triers of fact. You will weigh the evidence presented and decide
18
whether the government has proved beyond a reasonable doubt that the defendant
19
is guilty of the charges in the indictment. You must pay close attention to all of the
3
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1
evidence presented, and you must base your decision only on the evidence in the
2
case and my instructions about the law.
3
4
What Is and Isn't Evidence
5
What, then, is evidence? Evidence consists only of the testimony of
6
witnesses, documents and other things admitted as evidence, or stipulations agreed
7
to by the parties. Some of you probably have heard the terms "circumstantial
8
evidence" and "direct evidence." Do not be concerned with these terms. You are
9
to consider all the evidence given in this trial.
10
Certain things are not evidence and must not be considered by you. The
11
following is a list of what is not evidence:
12
First, arguments, statements, and questions by the lawyers are not evidence.
13
Nor are statements I make or questions I ask of a witness.
14
Second, objections to questions are not evidence. The lawyers have an
15
obligation to make an objection when they believe evidence being offered is
16
improper under the rules of evidence. You should not be influenced by the
17
objection or by my rulings on them. If the objection is sustained, ignore the
18
question and any answer that may have been given. If it is overruled, treat the
19
answer like any other. If you are instructed that some item of evidence is received
20
for a limited purpose only, you must follow that instruction.
4
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1
Third, testimony that I have excluded or told you to disregard is not
2
evidence and must not be considered.
3
Fourth, anything you may have seen or heard outside the courtroom is not
4
evidence and must be disregarded. You are to decide the case solely on the
5
evidence presented here in the courtroom.
6
7
Evaluating the Evidence
8
There is no formula to evaluate testimony or exhibits. For now, suffice it to
9
say that you bring with you into this courtroom all of the experience and
10
background of your lives. Do not leave your common sense outside the courtroom.
11
The same types of tests that you use in your everyday dealings are the tests that
12
you should apply in deciding how much weight, if any, to give to the evidence in
13 this case.
14
The law does not require you to accept all of the evidence admitted at trial.
15
In determining what evidence you accept, you must make your own evaluation of
16
the testimony from each of the witnesses and the exhibits that are received in
17
evidence.
18
It is essential, however, that you keep an open mind until you have heard all
19
of the evidence in the case. A case can be presented only step by step, witness by
20
witness, before all evidence is before you.
5
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1
As you know from experience, you can hear one person give his or her
2
version of an event and think it sounds very impressive or even compelling, and
3
yet, upon hearing another person's version of the same event - or even the same
4
person cross-examined with respect to the event - things may seem very different.
5
In other words, there may be another side to any witness's story.
6
You should use your common sense and good judgment to evaluate each
7
witness's testimony based on all of the circumstances. Again, I cannot emphasize
8
too strongly that you must keep an open mind until the trial is over. You should
9
not reach any conclusions until you have all the evidence before you.
10
As I mentioned during jury selection, this case has received, and will
11
continue to receive, significant attention in the media. To protect their privacy, I
12
have permitted witnesses, if they choose, to be referred to in open court by either
13
their first name or a pseudonym. The full names of the witnesses are known to the
14
Government, the defendant, and to the Court, and were shown to you during jury
15
selection. This process should not bear in any way on your evaluation of the
16
evidence in this case.
6
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1
Rules of Conduct
2
Finally, let me caution you about certain rules and principles governing your
3
conduct as jurors in this case. First, you must not talk to each other about this case
4
or about anyone who has anything to do with it until the end of the case when you
5
go to the jury room to decide your verdict. The reason for this requirement is that
6
you must not reach any conclusion on the charges until all of the evidence is in.
7
As I have said, keep an open mind until you start your deliberations at the end of
8
the case.
9
Second, do not communicate with anyone else about this case or about
10
anyone who has anything to do with it until the trial has ended and you have been
11
discharged as jurors. Anyone else includes members of your family and your
12
friends. And no communicating about the case means no communicating on your
13
cell phone, iPhone, Blackberry, text messaging, websites, internet chat rooms,
14
email, social media websites or applications (including Facebook, Instagram,
15
Twitter, LinkedIn, YouTube, Reddit, etc.) - or by any other means. I know in this
16
day and age there is temptation to look to these devices or means of
17
communication, but with your oath you are making a commitment to resist that
18
temptation. You may tell your family and friends that you are a juror in a criminal
19
case, but you may not tell them anything else about it until you have been
20
discharged by me.
7
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1
Third, do not let anyone talk to you about the case or about anyone who has
2
anything to do with it. If any person should attempt to communicate with you
3
about this case at any time throughout the trial, either in or out of the courthouse,
4
you must immediately report that to my Deputy, Ms. Williams, and to no one else.
5
Ms. Williams will report it to me. When I say report that communication to no one
6
else, I mean that you should not tell anyone, including your fellow jurors.
7
To minimize the probability of any such improper communication, it is
8
important that you go straight to the jury room when you come in in the morning
9
and that you remain in the jury room for the duration of the trial day. You should
10
not linger in the public areas of the courthouse, on this floor or elsewhere on your
11
way in and out.
12
Fourth, do not do any research or any investigation about the case or about
13
anyone who has anything to with the case on your own. Don't go visit any place
14
described in the trial. Don't read or listen to or watch any news reports about the
15 case. Don't go on the internet or use whatever digital or communications device it
16
is you use to see what you can learn to inform yourself about this matter.
17
Again, I know that in this day and age, there is temptation, but as I have
18
made clear throughout the process so far, this rule is very very important. That is
19
because your decision in this case must be made solely on the evidence or lack of
20
evidence presented at the trial. In other words, all that you need to know will be
8
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1
presented here in open court by the parties. This is critically important to ensuring
2
a fair trial - which I know that all of you would want if you were a party in this
3
Court and I have no doubt is what you want for the parties who are here today. I
4
expect you to inform me immediately through Ms. Williams if you become aware
5
of another juror's violation of these instructions.
6
Finally, each of you has been given a notebook and pen. That is because I
7
permit jurors to take notes. But you do not have to take notes. Notes are just an
8
aid to your own recollection. The court reporters in this case record everything
9
that is said in the courtroom and any portion of the testimony can be read back to
10
you during your deliberations. If you do take notes, be aware that note-taking may
11
distract you from something important that is happening on the witness stand.
12
Whether or not you take notes, rely on your own recollections, and don't be
13
influenced by the fact that another juror has taken notes. If you do take notes, all
14
notes must be left each day in the jury room. Ms. Williams will make sure that
15
they are secure.
16
From this point until the time when you retire to deliberate, it is your duty
17
not to discuss this case with anyone and not to remain in the presence of other
18
persons who may be discussing this case-this includes discussions even with
19
members of your own family, and your friends. In this regard, please understand
20
that the parties and counsel in this case have been instructed to have no contact
9
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Case 1:20-cr-00330-AJN Document 497 Filed 11/23/21 Page 11 of 11
1
with any of you, not even to offer a friendly greeting. So if you happen to see any
2
of them outside this courtroom, and they do not acknowledge you, say hello, or
3
make small talk, please do not take offense. They are not being rude - they are
4
simply following my instructions.
5
6
Conclusion
7
That concludes my preliminary instructions to you. Now we will begin with
8
the initial stage of the case, which, as I said to you, is opening statements, and we
9
are going to begin with the government.
10
Let me just note, as I said in the beginning of jury selection, we are in an
11
outfitted courtroom for COVID times. The witness will be in this Plexiglass box
12
that has a HEPA filter, and they will remove their mask to testify when we have
13
witnesses testify. The lawyer who will be questioning them and the lawyer during
14
opening statements will be in that Plexiglass box with the HEPA filter, and they
15
will be permitted to remove their mask while they provide opening statements, as
16 well.
17
So at this time I am going to ask all of you to give your undivided attention
18
to the lawyers as they make their opening statements.
10
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=== Page 1 ===
Event: Accepted: Epstein Op Meeting with FBI
Start Date: 2019-07-01 19:30:00 +0000
End Date: 2019-07-01 20:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-06-27 17:49:14 +0000
Date Modified: 2019-06-27 17:49:14 +0000
Priority: 5
DTSTAMP: 2019-06-27 17:39:27 +0000
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From:
(USANYS)"
To:
(USANYS)"
Subject: Accepted: Call/Meeting on Epstein
Date: Fri, 07 Dec 2018 11:31:35 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
PH
HADDON
FX
MORGAN
www.hmflaw.com
FOREMAN
November 1, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant
to Fed. R. Crim. P. 16(b)(1)(C).
I. EXPERT DISCLOSURE BY THE DEFENSE
A. Dr. Elizabeth Loftus
Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the
University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts
on the science of memory. In addition to her experience as an academic and clinical researcher,
she has been an expert witness or consultant in hundreds of cases. Her extensive experience and
credentials are recited in her curriculum vitae. Exhibit A.
It is expected that Dr. Loftus, a psychologist who specializes in the study of memory, will
focus on the memory aspects of this case. Based on her education, training, experience, and
research, her testimony will concern the workings of human memory, the effects of suggestion
on memory, the mechanism of creation of false memories, the characteristics of false memories,
how memory fades and weakens over time, and how memory becomes more vulnerable to
contamination. She will describe scientific research showing that false memories can be
EFTA00016268

=== Page 2 ===
November 1, 2021
Page 2
described with confidence, detail, and emotion, just like true memories. This can occur when
people come to believe in these experiences and are not deliberately lying. Dr. Loftus would
identify some of the suggestive activities that occurred in the current case.
Suggestive activities can explain how it is that a person might go from having no memory
of sexual abuse, and even denying sexual abuse, to later having "memories" for numerous
abusive acts, if the memories are false. She will explain the mechanism by which false and/or
distorted memories can be created as a result of post-event information and occurrences,
suggestion, influence or the like. She will also testify about the characteristics of false and/or
distorted memories. In particular "memories" can be described with confidence, detail and
emotion, even when they are false. She will point out some of the suggestive activities that
occurred in this case. She will explain how media coverage and other publications (including but
not limited to newspaper and magazine articles, news reports, television shows, documentaries,
books, podcasts, websites, etc.) and discussions/ conversations with others, can be sources of
suggestion. She will explain how, in a case like this one, suggestion can lead individuals to the
construction of distorted memories.
B. Park Dietz, M.D., M.P.H., PH.D.
Dr. Park Dietz is a psychiatrist specializing in forensic psychiatry with over 40 years of
experience. He has been previously qualified as an expert in psychiatry and forensic psychiatry.
Dr. Dietz received a bachelor's degree in psychology and biology from the Cornell
University College of Arts and Sciences (1970), an M.D. degree from the Johns Hopkins
University School of Medicine (1975), a Master's degree in Public Health from the Johns
Hopkins School of Hygiene and Public Health (1975), and a Ph.D. in sociology from the Johns
Hopkins University (1984). He completed psychiatric residency at the Johns Hopkins Hospital
(1975-77) and the Hospital of the University of Pennsylvania (1977-78), where he was Chief
Fellow in Forensic Psychiatry. He has been board certified in psychiatry by the American Board
of Psychiatry and Neurology since 1979.
He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School
of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School
of Law and a Professor of Behavioral Medicine and Psychiatry at the University of Virginia
School of Medicine. From 1982 to 1986, he was an Associate Professor of Law and of
Behavioral Medicine and Psychiatry at the University of Virginia Schools of Law and Medicine.
From 1978 to 1982, he was an Assistant Professor of Psychiatry at Harvard Medical School. In
those positions he taught and lectured on forensic psychiatry for diverse audiences, including law
students, practicing attorneys, law enforcement officers, psychiatry residents, forensic psychiatry
fellows, and practicing forensic psychiatrists and psychologists.
He is a Past President of the American Academy of Psychiatry and the Law, a
Distinguished Life Fellow of the American Psychiatric Association, and a Fellow of the
American Academy of Forensic Sciences. He has served on the editorial boards of the Bulletin
of the American Academy of Psychiatry and the Law, the Journal of Forensic Sciences,
Behavioral Sciences and the Law, the Journal of Threat Assessment and Management, and other
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=== Page 3 ===
November 1, 2021
Page 3
professional publications. He has authored more than 100 articles and book chapters, primarily
on forensic psychiatry.
He has conducted more than 1,000 evaluations of persons charged with crime and, in his
role as President of Park Dietz & Associates, Inc., has evaluated or supervised over 1,000
evaluations of allegations of sexual victimization. He has testified as an expert witness in
forensic psychiatry on hundreds of occasions, including testimony in criminal matters in federal
courts throughout the U.S. and the trial courts of nearly every state.
Dr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science.
Dr. Dietz's curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material
reviewed by Dr. Dietz.
His testimony may include, but will not be limited to, the following:
a. Opinions about Dr. Rocchio's Disclosed Opinions
The first use of the word "grooming" to refer to strategies that sometimes enable
nonforceful, nonthreatening, and nonviolent sexual victimization of minors was the proposition
that "the perpetrator involves children in sexual abuse through a grooming process in which a
combination of kindness, attention, material enticement, special privilege, and coercion are
expertly applied" (Conte, 1984, p. 558). Since then, this usage has been widely adopted by
social scientists, clinicians, journalists, and others. But this usage has some unintended
consequences that threaten the integrity of the adjudicative process, including these:
(1) Because use of the term "grooming" commonly assumes that the grooming party is
intentionally using these strategies to gain sexual access to children, to abuse them, and to
prevent them from disclosing the abuse, the word "grooming" has acquired meaning
beyond an objective description of behaviors; it imputes motive and intent without
adequate evidence of either.
(2) In the litigation context, "when 'grooming' is applied to such common and desirable
behaviors as being kind or attentive or helpful or caring, there is considerable risk of
misleading the fact finder into believing that these latter behaviors are well established
predictors of child sexual abuse," when they are not. Park Dietz, Grooming and
Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes
"grooming" as "a strategic pattern of behavior[]
that can take a variety of forms and
function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and
to build trust and attachment with their abuser." This vague opinion about "grooming"
carries the risk of imputing motive and intent to the Defendant, when the determination
of motive and intent is a task for the fact finder charged with determining the credibility
of witnesses, the weight of the evidence, and the ultimate issues. Moreover, this opinion
carries the risk of implying that innocuous and even desirable behaviors are associated
with nefarious or criminal conduct.
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=== Page 4 ===
November 1, 2021
Page 4
Moreover, grooming has no consistent definition, and concerns have been raised that
"there is no valid method to assess whether grooming has occurred or is occurring." Natalie
Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child
Sexual Abuse 957, 974 (2014).
In any particular population of alleged victims, patients, or plaintiffs-including those
whom Dr. Rocchio has treated or evaluated-the determination of whether grooming has
occurred is a subjective judgment hinging largely on the credibility of the individuals. Such
judgments have no known error rate and cannot be tested, verified, or reproduced.
Although the Government's Expert Notice regarding Dr. Rocchio's proposed testimony
is silent as to whether she is expected to impute a theory of "grooming-by-proxy" to the
Defendant, it is important to note that there is no generally accepted theory of grooming by third
parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a
phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for
herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to
provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy.
Dr. Dietz is aware of no authority-no journal articles, no studies, no tests, nothing-to
support a theory of grooming-by-proxy. Such a theory has not gained any acceptance (let alone
general acceptance) in the relevant community; it has not been peer-reviewed; it has not and
cannot be tested; and there is no known or potential rate of error.
Dr. Rocchio's opinion that "[i]ndividuals with particular vulnerabilities are often targeted
by perpetrators of sexual abuse" is a commonly accepted bit of clinical lore derived from the
frequent observation of highly vulnerable children among those children who allege sexual
abuse, but it is not based on empirical data regarding the likelihood of abuse among children
with varying degrees of vulnerability. To the extent that less vulnerable children, such as those
with intact families, attentive parents, good social support, little psychopathology, less prior
trauma, no substance use, and higher resilience are less likely to allege abuse than the more
vulnerable, the generalization could be proved weak or false, if only there were such empirical
data. And even if there were such data, it would be important to devise a means of verifying that
abuse did occur to those who allege it, which is a difficult task at best because of the pains so
many abusers take to avoid confession, witnesses, or physical evidence. The clinical, criminal
justice, and forensic populations from which the observation of prevalent vulnerabilities is
derived-including those clients whom Dr. Rocchio has treated or evaluated-rarely represent
groups in which all allegations of abuse have been verified by confession, witnesses, physical
evidence, or other means.
Other opinions put forth in the disclosure of Dr. Rocchio's proposed testimony also rest
on assertions that are untestable, cannot be reproduced, and have no known error rate.
b. Opinions About Hindsight Bias
Hindsight bias must be considered when evaluating sex abuse allegations and or
"grooming behavior." Many claims of sexual abuse of minors involve behaviors that are, in
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hindsight, labeled "grooming" or otherwise imputed as knowledge to onlookers. Hindsight bias
refers to the tendency to overestimate how predictable or foreseeable an event is after being
informed about the outcome of an event. Simply put, knowledge of the outcome of the event, i.e.
Epstein pleaded guilty to having sexual contact with post-pubescent minors, makes the
importance of pre-conviction behaviors obvious. Retrospective judgments about the
predictability or foreseeability of the outcome are systemically inflated or biased compared to
judgments made without information about the outcome. Hindsight bias refers to the tendency to
overestimate how predictable an event is after learning the outcome of the event (Fischhoff,
1975). For example, after a political election, people believe their pre-election estimates of the
outcome were closer to the outcome than they actually were (Blank, Fischer, & Erdfelder, 2003).
Hindsight bias has been discussed in over 800 scholarly articles across a variety of different
domains including medicine, financial decision making, consumer satisfaction, and within the
legal domain (see Roese & Vohs, 2012; Arkes, 2013; Strohmaier et al., 2021) and using a variety
of different experimental designs (Pohl & Erdfelder, 2016) and a variety of different stimuli such
as written vignettes, visual stimuli (e.g., Bernstein & Harley, 2007), and auditory stimuli (e.g.,
Bernstein, Wilson, Pernat, & Meilleur, 2012). Even individuals with specialized training and
expertise succumb to hindsight bias (Musch & Wagner, 2007). One notable study detected
hindsight bias among actual judges making civil liability decisions, in which judges with
outcome knowledge perceived the harm to be significantly more foreseeable than judges who did
not receive outcome information and were thus more likely to render a finding of negligence
(Oeberst & Goeckenjan, 2016). Another notable study detected hindsight bias in a sample of
mental health professionals who gauged the dangerousness of a psychiatric patient; again,
outcome knowledge affected the reported dangerousness and predictably of harm posed by the
patient (Beltrani et al., 2018).
Hindsight bias affects legal judgments. Civil or criminal prosecutions related to events
occurring decades ago may be compromised by this bias in many ways, from the investigation-
either ignoring evidence or attributing significance in hindsight-through the presentation of
evidence, to the deliberation of any factfinder. Awareness of the impact of the hindsight bias
should temper any claims that so called "grooming" behaviors should have been noticed and
either reported or avoided and that failing to do so constitutes knowledge or intent.
c. Opinions Related to the Halo Effect
The term "Halo effect" was coined by Thorndike (1920) a century ago. The Halo effect is
a cognitive bias in impression formation whereby the positive evaluation of one characteristic
has a radiating effect on how other, non-related characteristics of the individual are evaluated.
For example, one classic study found that physical attractiveness influenced evaluations of the
target's personality, life satisfaction, and expected future personal and occupational success -
despite the fact that no information about any of these attributes was provided (Dion et al.,
1972). Physical attractiveness has also been found to influence culpability judgments, with
attractive individuals being held less-responsible than unattractive individuals (Dion, 1972;
Efran, 1974). Halo effects have been found to be cued by factors other than attractiveness, such
as the described status of the target (Wilson, 1968), the name of the target (Harari & McDavid,
1973), and even one's mood when evaluating the target (Forgas, 2011). Studies have documented
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halo effects when making diagnoses of psychopathology, such that symptoms of one mental
disorder influence the interpretation of other symptoms indicative of other mental disorders and
vice versa (see e.g., DeVries, Hartung, & Golden, 2017).
Halo effects are a means to achieving cognitive consistency, which roughly refers to a
state in which attitudes, perceptions, beliefs, predictions, and thoughts are aligned. Cognitive
consistency serves many important goals. As noted by Read and Simon (2012), cognitive
consistency is "essential for reasons of parsimony and economy of effort, as well as to allow for
the predictability of, and hence adaptability to, subsequent encounters" (p. 67). Indeed, the noted
psychologist Leon Festinger "was convinced that the psychological need for cognitive
consistency is as basic as hunger and thirst" (Gawronski, 2012, p. 652). But because the world is
often not so neat, orderly, or unequivocal, humans engage in complicated reasoning processes to
impose consistency. These processes involve bi-directional reasoning in which "decisions follow
from evidence, and evaluations of the evidence shift toward coherence with the emerging
decision" (Simon, Snow, & Read, 2004, p. 814; Greenspan & Scurich, 2016). As a result,
perceptions and decisions become highly skewed toward one interpretation while alternatives are
neglected or dismissed, hence consistency is achieved. This reasoning process occurs
unconsciously, i.e., outside conscious awareness, and is not intentional self-deception.
Halo effects can have serious practical consequences. As noted by Forgas and Laham
(2016):
Once unjustified initial expectations are formed about a person, they can
easily become self-perpetuating with serious implications for how a target is
treated. If we expect a person to have positive characteristics, we may
selectively look for and find such features from the rich array of information
available (a self-fulfilling prophecy), and positive impressions may in turn
lead to preferential treatment in a range of domains:
interpersonal relations, the work place, the health and legal systems, and even
for decision making and consumer choices. (p. 286)
Like many people who achieve great power and wealth, Jeffery Epstein exploited the Halo effect
to surround himself with people who would serve his needs. At the most primitive level, his
wealth attracted those seeking for themselves some of what he had. At the most sophisticated
level, others with halos of their own-through any combination of power, influence, fame,
brilliance, attractiveness, social standing, or other positive characteristics-mingled with Epstein
for reasons of their own, and being seen in their company empowered him and made him look
above suspicion. In a videotaped interview with Steve Bannon, Epstein differentiated between
different kinds of power-such as Bill Clinton's political power, wrestlers' and weight lifters'
physical power, and Gerry Edelman's intellectual power-and acknowledged that he gravitated
to people of power. [CONFIDENTIAL] SDNY_GM_SUPP_00219000.mov.
The materials reviewed reflect that Jeffrey Epstein was a brilliant man who was flawed
by enduring personality traits familiar to psychiatrists as "Cluster B personality traits," found
among those with antisocial, narcissistic, borderline, and histrionic personality disorders.
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American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th
Ed., Arlington, VA: American Psychiatric Association (2013), pp. 659-672. These flaws
allowed him to use his brilliance to manipulate people to do his bidding and to compartmentalize
people into isolated cells in which none had complete information about his activities. These
were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual
behavior should it prove relevant.
d. Opinions Related to the Multiple Pathways to False Sex Assault
Allegations
Studies concerning the accurate reporting of alleged sexual assaults undermine the
assertions made by Dr. Rocchio to the extent they are based on uncorroborated allegations and
are also otherwise relevant here. False allegations of sexual assault do occur, and there are
multiple pathways to these false allegations of sexual assault.
Not all allegations of sexual assault are true. Unfortunately, there has been little work on
understanding the prevalence of false allegations or pathways to these, particularly in a sample
most relevant to a jury-currently adjudicated cases. A peer reviewed journal article has
proposed 11 pathways to false allegations of sexual assault: (a) lying, (b) implied consent, (c)
false memories, (d) intoxication, (e) antisocial personality disorder, (f) borderline personality
disorder, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation,
and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False
Allegations of Sexual Assault, 12J. Forensic Psychology Practice, 97. These pathways originate
in the psychological proclivities or state of the individual making these false allegations. The
descriptions of these pathways that follow include material drawn nearly verbatim from the
article by Engle and O'Donohue (2012), which was published before the latest edition of the
Diagnostic and Statistical Manual of Mental Disorders but nonetheless remains accurate in
characterizing certain personality disorders.
Lying: Lying involves the alleged victim knowingly making a false claim of sexual
assault. Humans do lie, and their lies can be difficult to detect. Often, humans lie because of
what they perceive as the favorable consequences for lying; for sexual assault these
consequences could be:
1. the severe negative consequences that the alleged perpetrator experiences,
2. secondary gain from victim status,
3. excusing behaviors or characteristics of the alleged victim (e.g., sexual
activity, pregnancy, sexually transmitted diseases)
4. financial gain.
Implied Consent: A fact finder's determination of whether consent was competently
given is often problematic, and some allegations are regarded as unfounded or false based on
determinations regarding consent before cases reach the stage of adjudication. A false allegation
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can arise when it was reasonable to believe consent was given but the alleged victim falsely
believes that it was not.
False Memory: The existence and prevalence of repressed memories is a source of
controversy, and yet research does exist demonstrating the successful implantation of fabricated
memories. In one of the first studies on the implantation of false memories, participants were
given short narratives of childhood experiences, purportedly obtained from relatives, and asked
to try to remember these experiences. Research by Elizabeth Loftus has revealed how subtle
information introduced after an event may alter the memory of that event. Loftus and her
students have conducted more than 200 studies with more than 20,000 participants
demonstrating how misinformation introduced after an event can induce people into creating
false memories.
Intoxication: Intoxication can substantially increase the likelihood of a false allegation of
sexual assault. Alcohol and other intoxicants pose a significant problem in sorting out the
validity of a sexual assault allegation. The information-processing errors induced by intoxicating
substances may cause confusion surrounding events that occurred while a person was
intoxicated. A person who does not accurately recall events that occurred while he or she was
under the influence or while experiencing the side effects of withdrawal from a substance may
attempt to make sense out of the disjointed and seemingly incoherent memories of events that
occurred while intoxicated. In an effort to make sense of and organize what memories are intact,
a person may confabulate or fill in the memory lapses with events that seem probable or which
for some reason they come to believe "must have" taken place.
Antisocial Personality Disorder: The essential feature of antisocial personality disorder is
a pervasive pattern of behavior that disregards and violates of the rights of others. It often begins
in early childhood or early adolescence and continues into adulthood. If an individual with
antisocial personality disorder is likely to lie to achieve power and pleasure, a false allegation of
sexual assault might be the means by which he or she attempts to achieve power over the falsely
accused. Falsely claiming someone sexually assaulted you can be an aggressive act and a lack of
remorse could allow the individual to file an allegation of sexual assault and maintain this
allegation with few, if any, conflicts of conscience. Thus, a pathway to a false allegation of
sexual assault can occur when an individual with antisocial personality disorder makes a false
claim of assault.
Borderline Personality Disorder: Borderline personality disorder (BPD) is a serious
mental condition characterized by affective dysregulation, impulsiveness, difficulties in
interpersonal relationships, and difficulties with self-image. Of particular note is the rapid
switching from idealization to devaluation, impulsivity, and manipulative features of borderline
personality disorder. The instability of relationships experienced by an individual with BPD may
be rooted in the tendency to quickly switch from idealizing significant others or lovers to
devaluing them. This sudden change in conceptualization of a partner is often caused by feeling
that the partner is not caring enough or giving enough or by suspicion of abandonment. The rapid
shifting between idealizing and demonization may bring about a change in perspective such that
a relationship that was viewed idealistically in the past is now seen through the devalued lens of
abuse or mistreatment. Past events then may become construed as "abuse" and may lead a person
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with BPD to believe he or she is a victim of sexual assault. Previous research has found that two
of the three major motivations to file a false allegation of rape were attention-seeking and
revenge. The switch from idealization to devaluation of the relationship and/or relationship
partner may spur a desire for revenge for any past behaviors that are, in the devaluation phase,
newly construed as mistreatment. Also, there is some evidence that individuals with BPD engage
in behaviors that are viewed as "manipulative." Manipulative behaviors are often outside the
conscious awareness of the individual and are learned through positive reinforcement, as
manipulation frequently results in positive outcomes for the manipulator. Thus, an individual
with BPD may use a sexual assault allegation as a way of impacting a third party for some
desired outcome.
Histrionic Personality Disorder: Diagnostic criteria for histrionic personality disorder
include: 1) feeling uncomfortable in situations in which he or she is not the center of attention; 2)
interactions with others are often characterized by inappropriate sexually seductive or
provocative behavior; 3) displaying rapidly shifting and shallow expressions; 4) consistently uses
physical appearance to draw attention to the self; 5) has a style of speech that is excessively
impressionistic and lacking in detail; 6) shows self-dramatization, theatricality, and exaggerated
expression of emotion; 7) is suggestible (i.e., easily influenced by others or circumstances), and
8) considers relationships to be more intimate than they actually are. Other relevant behaviors
include the tendency to play out stereotyped roles in their relationships with others; an intense
desire for novelty and excitement; and the upset and depression that may follow periods in which
they received little attention. Filing a false allegation of sexual assault may serve to benefit
individuals with histrionic personality disorder in several important ways. The sexualized
behavior of individuals with histrionic personality disorder can lead to sexual relationships that
may be used to seek attention (e.g., having sex with a person and telling all of their friends about
it). Filing a false sexual assault claim may regain lost attention, either from the desired partner or
from other individuals, providing a novel and exciting environment that may be stimulating to a
person who is histrionic. They may enjoy the large amounts of attention received for filing a
sexual assault charge and for the "victim" role that can be played out in other relationships (a
dynamic also common in false allegations by those with borderline personality disorder). In
times when attention is not being received to the desired level, a false allegation of sexual assault
may help to pull individuals with histrionic personality disorder out of their depressed state.
Delirium: Delirium is a disturbance of consciousness that is accompanied by a change in
cognition that cannot be better accounted for by a preexisting or evolving dementia. Relevant to
this pathway are the perceptual disturbances that may be present, including misinterpretations,
illusions, or even hallucinations. Many substances induce delirium, particularly in excessive
doses.
Psychotic Disorders: The term psychotic generally refers to conditions that are marked by
delusions, hallucinations, or markedly illogical thinking. Such conditions cause gross
impairments in functioning. Studies investigating the content of delusions have found delusions
that are sexual in nature are not uncommon and occur more often in women than in men. Some
cases of sexual delusions have been documented. These delusions may lead a person to claim
adamantly that sexual relations or events occurred that may be impossible or highly improbable.
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Dissociation: Dissociation is 'the lack of the normal integration of thoughts, feelings,
and experiences into the stream of consciousness and memory. Dissociation involves a
disruption or splitting off of memory, personality, identity, consciousness, or general perceptions
of the self and surroundings; it can be recurring, gradual, or transient. It is likely associated with
memory distortions. Thus, it is possible that in the event of a sexual assault, dissociation may
cause a person to fill in the parts of the experience that are not clearly remembered with events
that for them feasibly could have occurred. Of course, memory lapses will not necessarily be
filled in with a confabulated event, let alone a sexual one. However, individuals who dissociate
at a high frequency may seek to make their stories more coherent by adding details to an
incomplete memory that would make sense to them when considered in the context of the event.
Thus, these confabulations may lead to erroneous claims that have forensic relevance, including
who the perpetrator was, what happened, where, and how many times.
Intellectual Disability: Intellectual disability, is characterized by below average IQ and
adaptive functioning. Limitations in functioning include deficits in the acquisition of social,
occupational, academic, and general self-care skills. Intellectual disability has several etiologies
that often are related to biological or pathological processes affecting the central nervous system.
Many of the specific vulnerabilities that arise from intellectual disability overlap to some extent
with other disorders (e.g., autism spectrum disorders, cerebral palsy, fetal alcohol syndrome) and
individuals with other developmental disabilities may also have intellectual disability.
Intellectually disabled individuals, compared to individuals without ID, have vulnerabilities
related to memory and communication that the legal system may not be equipped to handle
adequately. Individuals with moderate-to-profound ID may have significant difficulty
communicating about the events that occurred because of language skills deficits or other
communication-interfering conditions (e.g., related neurological conditions). Research findings
indicate that communications skills are essential in filing a sexual assault charge; alleged victims
with mild ID were more likely than individuals with moderate or severe ID not only to file
sexual assault charges but to have their allegations confirmed. Difficulties with memory may
also complicate the investigation process for individuals with ID.
Changes in the core details of the allegation are often used by professionals as indices in
determining the credibility of a victim's claims. Peace and colleagues (2015) conducted a
narrative analysis of 147 sets of allegations of sexual assault across short (3 month) and long (6
month) intervals since the alleged event took place. In reviewing the existing literature, Peace
and colleagues found that genuine traumatic experiences have a demonstrable resiliency to
drastic impairments in recall. However, some inconsistencies especially in less core matters are
to be expected due to some less important details fading or varying over time. In examining their
sample of 147 allegations, the researchers discovered that truthful allegations contained more
detail relative to false allegations at each of the assessment intervals. Specifically, the researchers
found that fabricated allegations of traumatic experiences contained more inconsistent details
both at 3 months and 6 months. The total amount of detail for each type of allegation (true or
false) does tend to decrease over time. Additionally, as these figures suggest, the researchers
found that the number of details present in genuine reports continued to decrease over time
whereas fabricated stories 'levelled off" in detail.
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Hunt and Bull (2012) reviewed signs that can be used to differentiate true allegations of
sexual assault from false ones and concluded that the literature did not support the hypothesis
that emotional distress was predictive of the truthfulness of the allegation. This is consistent
across the literature, and emotional distress (e.g., crying) is not regarded as a reliable predictor of
the accuracy or truthfulness of an allegation. Additional research is needed, but at this point there
is little empirical support to indicate that being emotionally upset, distressed, or crying while
reporting an assault indicates that the report is more likely to be true. This is likely due to the fact
that such reactions can also occur in false allegations for various reasons, including a false
memory or an attempt to mislead by those who know this sort of reaction would be expected of a
true allegation.
Individuals who have been sexually assaulted have higher rates of mental disorders than
individuals who have not been sexually assaulted, and this includes significantly higher rates of
post-traumatic stress disorder, depression, bipolar disorder, drug use disorders, and alcohol use
disorders. Emily R. Dworkin, Risk for Mental Disorders Associated with Sexual Assault: A
Meta-Analysis, 21 Trauma, Violence, & Abuse (2020), pp. 1011-1028. Any of these mental
disorders that occur more frequently among those who have been sexually assaulted can affect
memory and recall, requiring assessment on a case-by-case basis.
Varying degrees of post-traumatic stress symptomatology occur in significant proportions
of victims following sexual assault and last for varying durations. Emily R. Dworkin, Anna E.
Jaffe, Michele Bedard-Gilligan, and Skye Fitzpatrick, PTSD in the Year Following Sexual
Assault: A Meta-Analysis of Prospective Studies, Trauma, Violence, & Abuse (2021)
https://doi.org/10.1177/15248380211032213. A substantial number of people never fully remit
from their PTSD even after many years, and variables associated with a longer time to remit
from an episode of chronic PTSD include a history of alcohol abuse and a history of childhood
trauma. Caron Zlotnick, Meredith Warshaw, et al., Chronicity in Posttraumatic Stress Disorder
(PTSD) and Predictors of Course of Comorbid PTSD in Patients with Anxiety Disorders, 12 J.
Traumatic Stress (1999), 89-100.
Symptoms of PTSD include distressing memories of the event; intense or prolonged
psychological distress at exposure to cues that symbolize or resemble an aspect of the traumatic
event; marked physiological reactions to cues that symbolize or resemble an aspect of the
traumatic event; avoidance or efforts to avoid distressing memories, thoughts, or feelings about
or closely associated with the traumatic event(s); and avoidance of or efforts to avoid external
reminders (people, places, conversations, activities, objects, situations) that arouse distressing
memories, thoughts, or feelings about or closely associated with the traumatic event(s).
American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th
Ed., Arlington, VA: American Psychiatric Association (2013), pp. 271-272. Individuals with
any of these symptoms are particularly unlikely to engage in continued communication or
friendly gestures with an alleged perpetrator, to wear clothing provided by an alleged perpetrator,
or to unnecessarily recreate a sexual assault event, any of which would be expected to elicit
intense distress.
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C. Dr. Ryan Hall
Dr. Ryan Hall performed an independent medical and psychiatric evaluation of
in 2009. Dr. Hall's curriculum vitae is attached as Exhibit D. His report is attached as
Exhibit E. Attached as Exhibit F is a list of material reviewed by Dr. Hall.
Dr. Hall is an expert in the field of forensic psychiatry and will offer opinions as such. He
will offer the opinions and diagnoses contained in his report, the bases for those opinions, and
the significance of the diagnoses and opinions. He will testify about the facts and circumstances
surrounding the evaluation, disclosures made by Ms.
and the fact that Ms.
did not identify Ms. Maxwell as a perpetrator of any abuse.
D. Bennett Gershman
Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of
Law of Pace University since its founding as the Pace Law School in 1976. He has also taught as
a visiting professor at Cornell Law School and Syracuse Law School. Prior to coming to Pace, he
was a prosecutor in the Manhattan District Attorney's Office and the New York State Anti-
Corruption Office. Professor Gershman's extensive scholarship has had an essential role in
establishing the study of prosecutorial misconduct, a subject at the intersection of criminal
procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the
author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and
practitioners.
We expect Professor Gershman to provide testimony on best practices to ensure the
integrity of any prosecution, focusing on investigation, witness preparation, media contact,
neutrality, obligations to provide accurate information, and relationship with crime victims, their
counsel, and case-related civil litigation. His extensive experience and credentials are recited in
his curriculum vitae, annexed as Exhibit G.
E. Robert Kelso
Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer
forensics, engineering and software technology. He holds Bachelor's and Master's degrees from
University of Colorado at Boulder in aerospace engineering and astrodynamics, respectively. He
is currently an adjunct professor at University of Denver teaching computer forensics at the
Master's level. He holds multiple computer forensics certifications including EnCE, CHFI, ACE
and AME. His curriculum vitae is attached. Exhibit H. Mr. Kelso has previously testified in
federal and state courts as an expert witness in computer forensics and has been appointed a
"special master" by the court on multiple occasions.
We anticipate that Mr. Kelso will testify about the user data associated with certain
devices seized and searched by the government's team in this case, documents and photographs
extracted from certain of those devices, and the metadata associated with certain documents and
photographs. He may also testify generally about computer forensic principles associated with
the creation of documents, storage and retrieval of digital documents and photographs, including
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the limits to the information that can be gleaned from the metadata. Mr. Kelso may testify in
rebuttal to any testimony offered by the government through Stephen Flatley. As trial
preparation proceeds, the defense will update the topics for Mr. Kelso if any arise.
F. John Lopez
Mr. Lopez was a Special Agent with the United States Department of the Treasury,
Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During
his tenure at IRS-CI, Mr. Lopez led the New York Asset Forfeiture Task Force and participated
in numerous criminal investigations involving complex fraud, corruption, bribery, tax evasion,
money laundering, and asset forfeiture. Since retiring from the IRS in 2013, Mr. Lopez has
worked as a financial investigator and consultant for several private investigation companies and
government enforcement agencies. He currently runs his own private financial investigation and
consulting company called JDL Services, Inc. Mr. Lopez holds a bachelor's degree in Business
Administration, Accounting and Finance from Pace University. His curriculum vitae is attached
as Exhibit I.
It is expected that Mr. Lopez will testify about his review of certain financial records
provided by the government in discovery. Specifically, Mr. Lopez will discuss various transfers
of funds that are reflected in the financial records and explain the information contained in the
financial records regarding those transfers. I
G. Gerald LaPorte
Mr. LaPorte is a Forensic Chemist and Document Dating Specialist with the firm Riley
Welch LaPorte &Associates Forensic Laboratories. He currently is the Director of Research
Innovation for Florida International University, Global Forensic and Justice Center. Prior to that,
he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of
Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and
has multiple professional honors in this field. His curriculum vitae is attached. Exhibit J
Defendant anticipates the receipt of documents produced by the government and
documents received pursuant to defense subpoena included but not limited to journal pages by
witness
These documents may require analysis regarding the dates of creation,
completeness, alteration and manipulation. When these documents are disclosed, Defendant will
seek to have them analyzed and present testimony on the analysis as needed.
1 The defense does not believe that the Court needs to qualify Mr. Lopez as an expert to
offer the proposed testimony. Nevertheless, we hereby notice Mr. Lopez as a potential expert
witness in an abundance of caution.
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H. Jennifer Naso
Ms. Naso is a Forensic Document Examiner who worked for and received specialized
training from the United States Secret Service as a Document Analyst. Ms. Naso has a Master's
of Science in Forensic Science and a Bachelor of Arts in Psychology. She has over 15 years of
experience examining and determining authorship and authentication of documents. Her
curriculum vitae is attached as Exhibit K.
Defendant anticipates the receipt of documents produced by the government and pursuant
to defense subpoena included but not limited to journal pages by witness
These
documents may require analysis regarding the dates of creation, completeness, alteration and
manipulation. When these documents are disclosed, Defendant will seek to have them analyzed
and present testimony on the analysis as needed.
II. RESERVATION OF RIGHTS
The defense reserves the right to amplify the disclosures contained herein based on
testimony and other evidence presented during the government's case-in-chief. The defense also
reserves the right to call additional expert witnesses and will promptly provide additional
disclosure notice.
III. RIGHT TO SUPPLEMENT
Ms. Maxwell reserves the right to supplement these opinions depending on the evidence
produced at trial. To the extent that any accuser claims to have been "groomed" or otherwise
testifies to the challenged opinions of Dr. Rocchio or other opinions properly rebutted by expert
testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of
the government's case in chief.
Very Truly Yours,
Jeffrey S. Pagliuca
Enclosures
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=== Page 1 ===
From:
To:
Subject: Automatic reply: 20-cr-330, United States V. Ghislaine Maxwell
Date: Mon, 28 Dec 2020 20:10:19 +0000
I will be on leave the week of December 28. I will be checking email regularly, but for matters requring
immediate attention, please contact
or call my cell,
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U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 6, 2019
VIA EMAIL
Martin G. Weinberg, Esq.
Martin G. Weinberg, P.C.
Boston, MA 02116
Reid Weingarten, Esq.
Michael Miller, Esq.
Steptoe & Johnson LLP
New York, NY 10036
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Mr. Weinberg:
The Government writes in response to your letters dated July 26, 2019, requesting
preservation and production of seven general categories of documents (the "July Letter"), and
August 1, 2019, requesting preservation and production in connection with a particular individual
(the "August Letter") (collectively, the "Letters"). Without conceding any obligation to preserve
any of the categories of documents, or, further, any obligation to produce responsive such
documents to the extent any exist, we will take reasonable steps to ensure the preservation of
documents we believe may be covered by the Letters' identified categories to the extent such
documents are already within the possession, custody, or control of the U.S. Attorney's Office for
the Southern District of New York (the "Office"). Other than documents already within the
possession, custody, or control of the Office, we will not be directing any other office or agency,
local, state, federal, or foreign, including any other office or component of the U.S. Department of
Justice, or any other nonparty to this case, including but not limited to victims or their counsel
(collectively, and without limitation, the "Non-Party Entities and Individuals"), to institute such
preservation.¹ Such agencies, departments, entities, and individuals are not parties to this
litigation, they are not a part of the prosecution team as that term has been defined under well-
1 The departments, agencies, entities, and individuals for which you assert this Office has "the
legal right or practical ability obtain" includes, without limitation, all 93 U.S. Attorney's Offices
across the nation, the Department of Justice Child Exploitation and Obscenity Section, the
Securities and Exchange Commission, the Department of Homeland Security, the New York [City]
Police Department, the Manhattan District Attorney's Office, the State Attorney's Office for the
15th Judicial District in and for Palm Beach County, the Palm Beach County Sheriff's Office, the
New Mexico Attorney General's Office, and any other "local, state, or foreign law enforcement
entities involved in any way in regulating or investigating the activities alleged in the Indictment
or related transactions." July Letter at 2-3. The scope of these requests is outlandishly overbroad.
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established Second Circuit law, and they are beyond the scope of this Office's disclosure
obligations in this case.
We expect to take all necessary steps to comply with our obligations under or pursuant to
Federal Rules of Criminal Procedure 16 and 26.2, Brady V. Maryland, and 18 U.S.C. § 3500
(collectively, this Office's "Obligations"). If you have a specific request to make to us under Rules
16 or 26.2, Brady, or $ 3500, we will address it appropriately.
With respect to the specific requests in the Letters, we note at the outset that a number of
those categories call for material that falls well beyond the scope of Rule 16 or any recognized
obligation under Brady and its progeny. In particular, we note that for purposes of discovery
demands, "a 'defendant must make a prima facie showing of materiality, and must offer more than
the conclusory allegation that the requested evidence is material." United States V. Abdalla, 317
F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States V. Urena, 989 F.Supp.2d 253, 261
(S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the
production of certain documents is meritless as a matter of law, then the requested documents are
not 'material' for purposes of Rule 16." Id. at 791.
Additionally, with respect to your assertion that the requested materials generally are
necessary due to an intended motion to dismiss based on a prior non-prosecution agreement
entered into by a U.S. Attorney's Office in a separate District, see July Letter at 3, we note that the
defendant has failed to make any showing, much less a threshold credible showing, of the kind of
due process violation that would make appropriate any discovery on an issue that is not a defense
on the merits of the charges themselves, but rather an independent assertion that charges were
brought for reasons that were improper or constitutionally invalid. See United States V. Armstrong,
517 U.S. 456, 463 (1996). Indeed, the defendant will be unable to make any kind of showing of
the conspiracy theory that there was activity inconsistent with any duty not to circumvent or
transfer a case from an immunizing district to another district, because-as we have proffered to
you and to the Court previously-this Office initiated its investigation without any transfer,
circumvention, or other influence from any other District.
Regarding the specific requests the July Letter does contain, we respond as follows:
First Request:
Any investigatory files provided to the United States Attorney's Office for the
Southern District of New York (or FBI agents working therewith) by the United
States Attorney's Office for the Southern District of Florida, the Middle District
of Florida, and/or the Northern District of Georgia (or FBI agents working
therewith).
We will produce materials consistent with our Obligations that are in the care, custody, or
control of this Office, irrespective of the source from which those files were obtained.
Second Request: Any investigatory files that were received or accessed by the United States
Attorney's Office for the Southern District of New York (or FBI agents working
therewith) that were sent or disclosed by or originated with the United States
Attorney's Offices of the Southern District of Florida, the Middle District of
Florida, and/or the Northern District of Georgia (or FBI agents working
therewith).
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Consistent with our response to the First Request, we will produce materials consistent
with our Obligations that are in the care, custody, or control of this Office, irrespective of the
source from which those files were obtained.
Third Request:
Communications regarding Mr. Epstein between and among "Main Justice"
(including the Child Exploitation and Obscenity Section) and the United States
Attorney's Offices for the Southern District of Florida, Middle District of
Florida, Northern District of Georgia, and the Southern District of New York.
To the extent any such communications constitute materials pursuant to our Obligations
and are in the care, custody, or control of this Office, we will produce such materials. However,
we are not currently aware that any such communications within this Office's care, custody, or
control do fall within our Obligations. To the extent this request seeks materials not subject to our
Obligations, they are vastly overbroad and fall well outside the scope of Rule 16 discovery or any
other of our Obligations. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16 does not authorize the
discovery or inspection of internal government documents made by an attorney for the government
or other government agent in connection with investigating or prosecuting the case); see also
Armstrong, 517 U.S. at 463 ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government
work product in connection with his case."). Accordingly, we will not produce any such
communications in the care, custody, or control of this Office that are not subject to our
Obligations.
As noted above, we also will not direct Non-Party Entities and Individuals to preserve or
produce materials that are not within the care, custody, or control of this Office.
Fourth Request: Any decision to initiate (or not initiate) criminal proceedings against Mr.
Epstein.
To the extent any such communications constitute materials pursuant to our Obligations
and are in the care, custody, or control of this Office, we will produce such materials. However,
we are not currently aware that any such communications within this Office's care, custody, or
control do fall within our Obligations. To the extent this request seeks materials not subject to our
Obligations, they are vastly overbroad and fall well outside the scope of Rule 16 discovery or any
other of our Obligations. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16 does not authorize the
discovery or inspection of internal government documents made by an attorney for the government
or other government agent in connection with investigating or prosecuting the case); see also
Armstrong, 517 U.S. at 463 ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government
work product in connection with his case."). Accordingly, we will not produce any such
communications in the care, custody, or control of this Office that are not subject to our
Obligations.
To the extent this request seeks materials not within the care, custody, or control of this
Officer, as noted above, we also will not direct Non-Party Entities and Individuals to preserve or
produce materials that are not within the care, custody, or control of this Office.
Finally, as described above and as previously represented to the Court and to defense
counsel, this Office initiated its investigation into the defendant independent of influence by any
other U.S. Attorney's Office.
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Fifth Request:
The NPA, including but limited to communications within the Department of
Justice, with counsel for Mr. Epstein, with representatives of the United States
Attorney's offices for the Southern and Middle District of Florida or the
Northern District of Georgia and/or counsel for the alleged victims.
To the extent any such communications constitute materials pursuant to our Obligations
and are in the care, custody, or control of this Office, we will produce such materials. However,
we are not currently aware that any such communications within this Office's care, custody, or
control do fall within our Obligations, with the possible exception of any communications with
counsel that include or constitute victim statements conveyed to this Office through victims'
counsel that are within the definitions of materials subject to Brady or $ 3500 obligations, any of
which will be disclosed promptly and based on the Court's schedule, respectively. To the extent
this request seeks materials not subject to our Obligations, they are vastly overbroad and fall well
outside the scope of Rule 16 discovery or any other of our Obligations. See Fed. R. Crim. P.
16(a)(2) (noting that Rule 16 does not authorize the discovery or inspection of internal government
documents made by an attorney for the government or other government agent in connection with
investigating or prosecuting the case); see also Armstrong, 517 U.S. at 463 ("[U]nder Rule
16(a)(2), [a defendant] may not examine Government work product in connection with his case.").
Accordingly, we will not produce any such communications in the care, custody, or control of this
Office that are not subject to our Obligations.
To the extent this request seeks materials not within the care, custody, or control of this
Officer, as noted above, we also will not direct Non-Party Entities and Individuals to preserve or
produce materials that are not within the care, custody, or control of this Office.
In particular, as described above, to the extent any communications between this Office
and victims or their counsel are subject to our Obligations, we will disclose them as appropriate;
however, we strongly oppose any effort to obtain the identity of victims at this stage through
meritless and unsupported suggestions of impropriety.
Sixth Request:
Communications with alleged victims (or their counsel), including but not
limited to consultations conducted in relation to the government's response to
the court's summary judgment order and proposed remedies in Jane Doe V.
United States, No. 08-cv-80736 (S.D.FI.).
This request for any and all communications with victims and their counsel, and apparently
intended to apply to this Office as well as all Non-Party Entities and Individuals, is grossly
overbroad and vastly beyond the scope of our Obligations. As described above, to the extent this
Office has within its care, custody, or control statements made by victims or their counsel that are
within the definitions of materials subject to Brady or $ 3500 obligations, any such statements or
materials will be disclosed promptly and based on the Court's schedule, respectively. Indeed, we
note that this Office has already made disclosures of certain victim and/or witness statements in
an abundance of caution.
As to the request for any and all communications with victims and their counsel beyond
those subject to our Obligations-a fishing expedition clearly intended to result in the disclosure
of the identities of the victims in this case-we will not produce such material.
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Seventh Request: Information provided by alleged victims (or their counsel) related to Mr.
Epstein prior to the return of the above-captioned Indictment.
This request for any and all information provided by victims and their counsel, and
apparently intended to apply to this Office as well as all Non-Party Entities and Individuals, is
grossly overbroad and vastly beyond the scope of our Obligations. As described above, to the
extent this Office has within its care, custody, or control information provided by victims or their
counsel that are within the definitions of materials subject to Brady or $ 3500 obligations, any such
statements or materials will be disclosed promptly and based on the Court's schedule, respectively.
Indeed, we note that this Office has already made disclosures of certain victim and/or witness
statements in an abundance of caution.
Similar to the above, as to the request for any and all information provided by victims and
their counsel beyond those subject to our Obligations, which is plainly intended to result in the
disclosure of the identities of victims in this case, we certainly will not produce such material.
Regarding the specific requests contained in the August Letter, all of which relate to a
particular employee of the U.S. Attorney's Office for the Southern District of Florida, to the extent
any such communications constitute materials pursuant to our Obligations and are in the care,
custody, or control of this Office, we will produce such materials. However, we are not currently
aware that any such communications within this Office's care, custody, or control do fall within
our Obligations. To the extent these requests seek materials not subject to our Obligations, they
are vastly overbroad and fall well outside the scope of Rule 16 discovery or any other of our
Obligations, as described above. Accordingly, we will not produce any such communications in
the care, custody, or control of this Office that are not subject to our Obligations. Additionally, to
the extent the requests of the August Letter seek materials not within the care, custody, or control
of this Officer, as noted above, we also will not direct Non-Party Entities and Individuals to
preserve or produce materials that are not within the care, custody, or control of this Office. In
connection with the August Letter, we further reiterate that the undersigned had no pre-indictment
contact with any individuals employed at the U.S. Attorney's Office for the Southern District of
Florida, and the investigation resulting in the charges in the above-captioned case was not initiated
by the provision of any investigative materials from any other U.S. Attorney's Office or other
Non-Party Entities or Individuals.
Very truly yours,
GEOFFREY S. BERMAN
United States Attornev
By:
Assistant United States Attorneys
Southern District of New York
Tel:
EFTA00016600


