# docs_fts_content

c1: EFTA00033955
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033955.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
I'll resend all the emails. There is a total of 4. I'll double check the attachment before resending.
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
ext. 6451
NYM/AW-Programs~@bop.gov
>>>
> 8/12/2019 3:35 PM >>>
When I try to open it says "document cannot be opened because it is corrupted or damaged"
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
Date: 8/12/19 3:33 PM (GMT-05:00)
To:
Cc:
Subject: Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am re: Epstein, Jeffrey Edward, Reg. No. 73618-054
(
)" 08/12/2019 15:33
Psych Observation 7/8/19 6 pm until 7/10/19 at 9 am (I/M companion utilized)
CONFIDENTIAL
SDNY_00009690
EFTA00033955


c1: EFTA00033630
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033630.pdf
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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Saturday, August 03, 2019
Beginning Count: 761
SHU: 77/5
Daily Sensitive Information:
M/W
I/M Melendez #85799-054 at Local Hosp. w/USMS Guards
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
761
77/5
Operations Lieutenant. The fire alarm and sprinkler system are
operational w/exception of Control Center Fire Panel. PREA
announcement conducted via the Institution Public Address System
and/or Radio. Restraint Equipment Cage inventory conducted. All
equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate/Facilities/R&D. Roof
Check completed. All secure. Temporary Chit Inventory: #1:2;
#2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0
12:00
Institution Count in progress
AM
12:00
NYPD Phone Check #2735
AM
12:08
Body Alarm testing in progress
AM
12:30
Watch Calls cont.
AM
12:31
Body Alarm testing completed
AM
12:37
Good Verbal count announced
AM
12:41
Clear Institution count announced
761
77/5
AM
3:00 AM
Institution Count in progress
3:21 AM
Good Verbal count announced
3:25 AM
Clear Institution count announced
761
77/5
5:00 AM
Institution Count in progress
5:36 AM
Good Verbal count announced
5:48 AM
Clear Institution count announced
761
77/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
761
77/5
STG International Terrorist phone calls monitored:
WITSEC inquiry was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 761 SHU: 77; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00008932
EFTA00033630

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W Saturday, August 03, 2019
Beginning Count: 761
SHU:77/5
D/W
Daily Sensitive Information:
I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards.
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
761
77/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted.
All operative w/the exception of Rear Gate. Roof Check
completed. All secure. Temporary Chit Inventory: #1:0; #2:5;
#3:5; #4:6; #5:6; #6:5; Hosp:0
Daily Hand Stamp :GPKJ /RIGHT HAND
8:00 AM
NYPD Phone Check #1892
8:15 AM
Body Alarm Test Initiated.
8:41 AM
Body Alarm Testing Complete.
10:00 AM
Institution count
10:43 AM
Good verbal announced
10:49 AM
Clear count announced
761
77/5
11:00 AM
Mainline feeding in progress.
12:00 PM
Religious service in progress
1:10 PM
Religious service complete
3:45 PM
Institutional lockdown for count.
761
77/5
4:00 PM
Relieved of duties by Lt.
E/W Operations Lieutenant.
761
77/5
Visitation: 5 SOUTH
Inmates
Adults
Children
Total
13
16
3
32
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Ops Lt
Ending Count: 761 ; SHU:77 ; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
CONFIDENTIAL
SDNY_00008933
EFTA00033631

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHU: 77/
SHIFT-DAY-DATE: E/W Saturday, August 3, 2019
Beginning Count: 761
5
Daily Sensitive Information.
E/W
I/M I/M Melendez #85799-054 at Local Hosp w/USMS Guards.
I/M Benjamin #86463-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch
Operations Lieutenant. Unable to conduct PREA announcement over
the Institution Public Address System, due to, system malfunction.
4:00 PM
Restraint Equipment Cage inventory conducted. All equipment
761
77/5
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:01 PM
NYPD Phone Check #2031
4:03 PM
Body Alarm testing in progress.
4:14 PM
Body alarm testing completed.
4:37 PM
Good verbal announced.
4:51 PM
Clear institutional count.
761
77/5
6:00 PM
Watch call in progress
6:37 PM
+1 Hospital return; I/M Melendez #85799-054
762
77/5
8:01 PM
Trash run in progress
8:40 PM
Trash run complete
10:00
Institutional count in progress.
PM
10:25
Good verbal count announced.
PM
10:29
Clear institutional count announced.
762
77/5
PM
12:00
continues duties as the M/W Lieutenant.
762
77/5
AM
VISITING:
INMATES
ADULTS
CHILDREN
TOTAL
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Ops. Lt.
Ending Count: 762 ; SHU: 77; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
CONFIDENTIAL
SDNY_00008934
EFTA00033632


c1: EFTA00031976
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c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031976.pdf
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: 2020-09-28 GM letter to Judge Nathan re discovery from other agencies v2.rc.docx
Date: Wed, 30 Sep 2020 16:41:01 +0000
Attachments: 2020-09-
28_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_v2.rc.JMM.docx
Couple new comments.
From:
(USANYS)
>
Sent: Wednesday, September 30, 2020 11:52 AM
To:
(USANYS)
Subject: RE: 2020-09-28 GM letter to Judge Nathan re discovery from other agencies v2.rc.docx
When you are done, send it back to me as I have a couple more nits to add.
From:
(USANYS)
Sent: Wednesday, September 30, 2020 11:09 AM
To:
(USANYS)
Subject: 2020-09-28 GM letter to Judge Nathan re discovery from other agencies v2.rc.docx
I've added some minor edits and a few comments.
EFTA00031976


c1: EFTA00033984
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033984.pdf
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=== Page 1 ===
Please see attached and below from
and Lt.
It seems more relevant for you to do this report since you saw
him yesterday for the SRA.
>>>
7/24/2019 7:54 AM >>>
send it to her
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
>>>
7/24/2019 7:51 AM >>>
Will
take care of this? Since she saw him for the SRA yesterday, closest to the incident? Seems more relevant for her than I.
Do you agree?
>>>
7/24/2019 7:37 AM >>>
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
CONFIDENTIAL
SDNY_00009763
EFTA00033984


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=== Page 1 ===
From:
To:
Subject: Fwd: State Attorney's Office - New Document Available - Case No 2020PR000426AMB
Date: Mon, 14 Sep 2020 19:44:11 +0000
Begin forwarded message:
From:
Date: September 14, 2020 at 3:41:21 PM EDT
To:
Subject: State Attorney's Office - New Document Available - Case No 2020PR000426AMB
Reply-To:
There is a new file available.
Case Number 2020PR000426AMB
Defendant Name JEFFREY E EPSTEIN
Please click here to download the file.
When setting up initial account, please be sure to check your spam/junk email folder for the notification email.
Sent By
EFTA00032128


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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com
To:
Subject: Bridgegate To Reach High Court In McDonnell's Shadow
Date: Tue, 14 Jan 2020 08:27:22 +0000
Law360 White
Collar
WHITE COLLAR
Tuesday, January 14, 2020
Follow Law360
TOP NEWS
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Analysis
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Cadwalader Wickersham
Jurors on Monday heard of "lies, corruption and greed" as the trial began for
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Federal prosecutors kicked off the money laundering trial of Sanovas Inc.
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medical device startup executive embezzled nearly $3 million from investors
Hogan Lovells
- money he spent on a mansion, a Maserati and a $50,000 diamond ring.
Javerbaum Wurgaft
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Keker Van Nest & Peters
A Manhattan state court judge presiding over the rape trial of Harvey
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Weinstein warned prospective jurors - including supermodel Gigi Hadid -
King & Spalding
not to post on social media about their experience, threatening possible jail
Kirkland & Ellis
time for anyone violating a court order against it.
Lewis Baach
EFTA00032549

=== Page 2 ===
Read full article
Linklaters
SECURITIES
Lucas Magazine
Mayer Brown
Asset Manager Pleads Guilty In $164M Pump-And-Dump Scam
McGuireWoods
The accused mastermind of a $164 million international pump-and-dump
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stock scheme pled guilty to securities fraud and conspiracy to commit
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Nutter McClennen
judge that prosecutors outsourced their investigation into spoofing to the
bank and its counsel at Linklaters, Cadwalader and Kirkland, raising the
O'Melveny & Myers
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6 documents attached Read full article
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Paul Weiss
FDA Slams Theranos Execs' "Unprecedented" Doc Bid
Pierce Bainbridge
A U.S. Food and Drug Administration attorney on Monday criticized demands
Proskauer Rose
by former Theranos CEO Elizabeth Holmes and another executive for
QEB Hollis Whiteman
internal documents to help them prepare their criminal defense against fraud
charges, saying the scope of the requests are "wholly unprecedented" and
Reed Smith
diverting the agency's valuable resources.
Riemer & Braunstein
Read full article
Robinson Bradshaw
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Saul Ewing
Qatar Move To Steer Biz To Barclays There 'In Black & White'
Saveri & Saveri
Shaheen & Gordon
There is clear evidence that Qatar tried to steer business toward Barclays
after it struck a controversial side deal with the country that prosecutors
Sideman & Bancroft
allege was used to hide payments linked to emergency fundraising, a former
Skadden
bank executive told a jury on Monday.
Steptoe & Johnson LLP
Read full article
Sullivan & Cromwell
'Cocaine Cowboy' Can't Kick Conviction For Car Fraud
Three Raymond Buildings
Todd & Weld
Former drug trafficker Michael "Mickey" Munday couldn't shake his fraud
conviction and 12-year prison sentence after the Eleventh Circuit upheld a
Watkins & Eager
Florida federal court's ruling over a $1.7 million vehicle "title-washing"
White & Case
scheme Monday.
Wilkinson Walsh
Opinion attached Read full article
Williams & Connolly
WilmerHale
Banks Call TelexFree Suit Revision A Waste of Time
Zeichner Ellman
A slew of financial services providers including Wells Fargo, Bank of America,
TD Bank and PwC pushed back Friday in Massachusetts federal court
COMPANIES
against an attempt to revise allegations linking them to the TelexFree Ponzi
American Bankers Association
scheme, arguing the repeat bids for revision are wasting the court's time.
1 document attached Read full article
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Bank of America Corp.
Pierce Bainbridge Says Ex-Partner's Suit Must Be Arbitrated
BuzzFeed Inc.
Pierce Bainbridge has told a New York state court that a contentious
Centerview Partners LLC
defamation suit by a former partner belongs in arbitration, saying that the
Clearspire
partner signed an arbitration agreement when he was hired.
Read full article
DISH Network LLC
Deutsche Bank AG
HEALTH
Deutsche Telekom AG
Facebook Inc.
Ex-Insys Exec Gets Nearly 3 Years For Opioid Kickbacks
International Payout Systems Inc.
EFTA00032550

=== Page 3 ===
A former Insys Therapeutics Inc. executive was sentenced to 33 months in
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prison for his role in an opioid kickback scheme after a Massachusetts
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federal judge heard emotional testimony Monday from patients who said their
Maserati North America Inc.
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Oxford University Press Ltd.
Insys Judge Wonders If Potential Punishment Is Too Harsh
PricewaterhouseCoopers
International Ltd.
The Massachusetts federal judge overseeing the case of seven former Insys
Therapeutics Inc. executives convicted in an opioid kickback scheme said
ProPay Inc.
Monday that the lengthy sentencing guidelines and the government's $306
Sprint Nextel Corporation
million dollar restitution ask may be too severe for the conduct at issue.
T-Mobile US Inc.
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TelexFree LLC
COMPETITION
The New York Times Co.
Toronto-Dominion Bank
Justices Skip Case Over 'Per Se' Rule In Antitrust Convictions
Wells Fargo & Co.
The U.S. Supreme Court declined Monday to review criminal antitrust
ZTE Corp.
convictions handed down against three California residents for bid-rigging,
despite arguments from criminal justice nonprofits that the way federal
GOVERNMENT AGENCIES
prosecutors went after the violations is unconstitutional.
California Labor and Workforce
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Development Agency
Centers for Medicare & Medicaid
EXPERT ANALYSIS
Services
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FinCEN's Most Lethal AML Weapon Against Foreign Banks
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As the U.S. Financial Crimes Enforcement Network plans to increase its use
Financial Crimes Enforcement
of so-called special measures under the USA Patriot Act, it is a good bet
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FinCEN will focus its efforts to exile foreign banks it believes pose a money
laundering threat to the U.S. financial system, says Arthur Middlemiss at
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Judging A Book: Dyk Reviews 'Democracy And Equality'
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Atrium has reportedly laid off a number of attorneys and staff just over two
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Law firm managers scanning the horizon in early 2020 have an increasingly
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pessimistic outlook on both firm performance and the economy, according to
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a new report, with firm leaders' confidence in the U.S. economy dipping
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Ex-Kasowitz Atty Says He Was Victim Of Racial, Gay Bias
A former partner at Kasowitz Benson Torres LLP is suing the firm in California
court, alleging he faced discrimination because he's black and gay before
EFTA00032551

=== Page 4 ===
being suddenly fired.
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Harvard Law School professor Lawrence Lessig launched what he called a
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Epstein.
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EFTA00032552


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=== Page 1 ===
From:
"
)"
To:
Cc:
)"
)"
Subject: FW: [EXTERNAL] Letter from Client
"Confidential Communication"
Date: Fri, 19 Nov 2021 22:46:24 +0000
Attachments: PRIVATE_AND_CONFIDENTIAL_2.pdf
Hi
Would you please add this to NTW for
?
Thanks,
From:
Sent: Friday, November 19, 2021 3:38 PM
To:
is
>;
Subject: Fwd: [EXTERNAL] Letter from Client
"Confidential Communication"
Begin forwarded message:
From:
Date: November 19, 2021 at 3:28:49 PM EST
To:
)"
>,
)"
i
To All Concerned: Please find the attached letter authored by my Client
Cordially,
EFTA00032598


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=== Page 1 ===
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
2. Gebremariam #79792-007 (Forensic)
Thank you,
CONFIDENTIAL
SDNY_00009863
EFTA00034015


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=== Page 1 ===
Cc:
From:
Sent:
Mon 8/12/2019 7:56:04 PM
Subject:
Psych Observation 7/24-30/19 (I/M companion utilized) re: Epstein, Jeffrey Edward, Reg. No.
73618-054
TEXT.htm
ge
Epstein Psych Observation 7-24-30-2019.pdf
Psych Observation 7/24-30/19 (I/M companion utilized)
CONFIDENTIAL
SDNY_00009174
EFTA00033714


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=== Page 1 ===
From:
<
>
To:
(USANYS)
Cc:
<
Subject: Epstein
Date: Tue, 13 Aug 2019 16:19:17 +0000
Good afternoon
I hope all is well. I understand the prosecution team has been walled off from the investigation. Do you have access to his
records from his prior incarceration? If not, do you have a contact for his prior facility or the USAO in Florida? I have been
asked to track down certain documentation in reference thereto in relation to the various investigations into the incident this
past weekend.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
EFTA00032292


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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com>
To:
Subject: Ex-Braskem Exec Granted $30M Bail In Bribery Case
Date: Fri, 13 Dec 2019 09:13:45 +0000
Law360 White
Collar
WHITE COLLAR
Friday, December 13, 2019
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Ex-Braskem Exec Granted $30M Bail In Bribery Case
The former CEO of Brazilian oil company Braskem satisfied a reluctant
magistrate judge on Thursday that cash and investments worth about $30
million, or around half his wealth, will be enough to ensure he appears in
Brooklyn to face charges of conspiring to bribe officials in his home country.
Read full article
House Panel Subpoena For Trump Docs Invalid, Justices Told
A House committee's subpoena for President Donald Trump's financial
records should be invalidated because the request was made outside
Congress' authority and poses constitutional concerns that warrant review by
the U.S. Supreme Court, Trump's attorneys told the court Thursday.
Listen to our new podcast here
Brief attached Read full article
LAW FIRMS
HP Accuses Autonomy CEO Of Repeated Lies At Trial
4 Stone Buildings
Autonomy founder Mike Lynch repeatedly lied in his retelling of events
BakerHostetler
leading up to Hewlett-Packard's ill-fated acquisition of his software firm, HP's
Black Srebnick
lawyer told a London judge as the trial over the technology giant's $5 billion
fraud claim wound down Thursday.
Blackstone Chambers
Read full article
Blank Rome
Boies Schiller
10 Former NFL Players Charged In Medical Benefits Fraud
Buckley King
Ten former NFL players including ex-Washington Redskins running back
Campbell & Williams
Clinton Portis have been indicted in Kentucky federal court on charges they
defrauded an NFL health plan out of more than $3.4 million.
Clarence Dyer
2 documents attached Read full article
Clifford Chance
Consovoy McCarthy
Feds Say 'Varsity Blues' Dad Isn't Being Denied Evidence
Davenport Evans
A former casino executive has all he needs to defend himself against charges
Epstein Becker Green
he bribed his daughter's way into college, federal prosecutors said
Essex Court Chambers
Wednesday as they pushed back against a claim that they are withholding
Foley & Lardner
FBI reports that could help show his innocence in the "Varsity Blues" case.
Fountain Court Chambers
1 document attached Read full article
Freeman Mathis
MVP: Kaplan Hecker's Sean Hecker
Hirsch & Westheimer
Kaplan Hecker & Fink LLP's Sean Hecker earned a rare acquittal of market
Hunton Andrews Kurth
manipulation allegations against a Barclays trader, and he's helped build a
Irell & Manella
robust white collar practice at his emerging boutique firm, earning him a spot
Jackson Lewis
as one of Law360's 2019 White Collar MVPs.
Jenner & Block
Read full article
John H. Haskin & Associates
EFTA00032947

=== Page 2 ===
SECURITIES
Kaplan Hecker
Kerr Russell
Shopin CEO Cops To $42.5M Fraudulent Crypto Offering
Kirkland & Ellis
The CEO of online retail platform Shopin pled guilty to securities fraud for a
Krieger Kim & Lewin
cryptocurrency scheme in which he lied to investors about the company and
Latham & Watkins
held a $42.5 million unregistered initial coin offering, the New York attorney
general's office announced Thursday.
LeClairRyan
Read full article
Lewis Brisbois
Michael Best
Rabobank Sues Ex-Trader For Exit Package Over Libor Fight
Michelmores LLP
Rabobank has demanded that a former trader repay a £119,000 ($157,000)
Milbank LLP
exit package that he allegedly violated by suing the Dutch lender for not
Modus Law
coming to his defense when U.S. prosecutors charged him with rigging a key
benchmark interest rate.
Morgan Lewis
Read full article
Nixon Peabody
O'Melveny & Myers
LEGAL ETHICS
Paul Weiss
Quinn Emanuel
Exonerated Texas Judge Fights For Spot On 2020 Ballot
Robbins Russell
A former Texas state judge who was exonerated of bribery and money
laundering convictions in 2017 is looking to the state's highest court for help
Robinson Curley
to get on the March 2020 primary ballot.
Scott H. Palmer PC
Petition attached Read full article
Simmons & Simmons
Tache Bronis
Ex-Court Worker Gets 2 Years For Lying In Pay-To-Play Probe
Travers Smith
An Illinois federal judge on Thursday gave a former associate clerk with the
Welsh & Recker
Cook County Circuit Court two years in prison for lying to a grand jury, saying
if people believe they are above the rule of law, "the entire foundation of our
Williams & Connolly
democracy grinds to a halt."
Willkie Farr
Read full article
Wright Close
HEALTH
COMPANIES
American Federation of State,
Judge Urges Gov't, Esformes To Work Out Atty Fee Deal
County and Municipal Employees
A Florida federal judge on Thursday urged prosecutors and attorneys for
Bed Bath & Beyond Inc.
convicted nursing home mogul Philip Esformes to work together on an
Braskem SA
agreement to unfreeze certain assets to cover millions in unpaid legal bills
CRST International Inc.
from Esformes' trial to avoid a complicated legal battle over what fee amount
is reasonable.
Cigna Corp.
Read full article
Citigroup Inc.
Credit Suisse Group AG
GOVERNMENT CONTRACTS
Deutsche Bank AG
Ethereum GmbH
Biz Manager Gets 2½ Years Over $2.2M DOD Parts Scam
Exxon Mobil Corp.
A California man was sentenced to 2½ years in federal prison for his part in a
scheme to sell the U.S. Department of Defense $2.2 million worth of
Google Inc.
defective parts for military weapons systems, the U.S. District Attorney's
Greyhound Lines Inc.
Office for the Southern District of Ohio announced Thursday.
Hewlett Packard Enterprise Co.
Read full article
Industria de Diseno Textil SA
Ironshore Inc.
TAX
MGM Resorts International
Businessmen Can't Quash Citi Subpoena In Tax Privacy Case
Mazars USA LLP
Two Texas businessmen cannot quash a government subpoena seeking
NantKwest Inc.
clarification on whether Citibank possessed their tax information because it
National Football League Players
may shed light on their suit alleging the information was unlawfully disclosed
Association
by the IRS, a South Dakota federal court ruled.
Pac-12 Enterprises LLC
Order attached Read full article
Petrobras
EFTA00032948

=== Page 3 ===
SPORTS & BETTING
Protect Democracy Project Inc.
Rabobank
NFL Players Union Accused Of Harassing Agent
Rolls-Royce
An NFL player agent is suing the NFL Players Association for $2.8 million,
State Bar of California
claiming he's lost all his clients and future prospects after the association
State Bar of Wisconsin
harassed him and ruined his reputation over criminal charges that were
dismissed.
Systemax Inc.
1 document attached
Read full article
Temple University
Tesla Inc.
CONSUMER PROTECTION
The Princeton Review Inc.
Vinmar International Ltd.
Pa. AG, Temple Reach Deal On Online MBA Rating Inflation
Washington Redskins
Pennsylvania Attorney General Josh Shapiro announced on Thursday that
Wells Fargo & Co.
Philadelphia-based Temple University had signed a deal to resolve claims the
university's business school knowingly used false data to boost the rankings
Wynn Resorts Ltd.
of its online MBA program.
GOVERNMENT AGENCIES
Read full article
Equal Employment Opportunity
Commission
LEGAL INDUSTRY
Federal Bureau of Investigation
Boies Schiller Names New Generation Of Leaders
Financial Conduct Authority
Legal powerhouse Boies Schiller Flexner LLP has put forward two partners to
Illinois Attorney General's Office
potentially take over the firm from its founders, including famous litigator
Internal Revenue Service
David Boies, the firm confirmed on Thursday.
National Transportation Safety
Read full article
Board
New York Attorney General's Office
Tesla's 3rd General Counsel In A Year Leaves Automaker
Pennsylvania Attorney General's
In yet another general counsel shakeup this year, Tesla Inc.'s top lawyer and
Office
a longtime insider has left the electric automaker after just 10 months in the
role, moving on to lead the legal team at an artificial intelligence company,
Securities and Exchange
Commission
the startup announced Thursday.
Read full article
Texas Supreme Court
U.S. Attorney's Office
Latham & Watkins Launches Free Onsite Health Clinic
U.S. Bankruptcy Court for the
Latham & Watkins LLP has opened an onsite clinic at its downtown Los
Eastern District of Virginia
Angeles office, which offers both physical and mental health care options for
U.S. Department of Defense
free to employees, the firm announced on Thursday.
U.S. Department of Justice
Read full article
U.S. District Court for the District of
Massachusetts
3 Tips For Women Who Want To Argue At The Supreme Court
U.S. District Court for the Eastern
Women should think outside the billable-hour box and assert themselves
District of Kentucky
more to land opportunities to argue before the U.S. Supreme Court,
U.S. District Court for the Eastern
according to members of a panel who discussed the issue Thursday in
Chicago.
District of Michigan
Read full article
U.S. District Court for the Eastern
District of New York
Hotelier Seeks $28M Deal Outside LeClairRyan's Ch. 7
U.S. District Court for the Northern
A Virginia hotel operator and former LeClairRyan PLLC client wants out of the
District of Illinois
automatic stay in the defunct firm's bankruptcy proceedings so it can go after
U.S. District Court for the Southern
LeClairRyan for $28 million and resolve a malpractice suit lodged before the
District of Florida
bankruptcy, according to a motion filed Thursday.
U.S. Patent and Trademark Office
Read full article
U.S. Supreme Court
United States District Court for the
Wis. Bar Dodges 1st Amendment Fight Over Mandatory Dues
District of South Dakota
A Wisconsin federal judge has tossed a lawsuit by two lawyers who objected
United States District Court for the
to paying dues to the state's bar association, the latest case where attorneys
Southern District of Ohio
are challenging the requirement on First Amendment grounds.
United States District Court for the
Read full article
Western District of Wisconsin
EFTA00032949

=== Page 4 ===
Law360's Weekly Verdict: Legal Lions & Lambs
Paul Weiss locked down a spot on the legal lions list this week with a
favorable decision for ExxonMobil in a landmark climate change-related
investor fraud case, while a $20 million verdict against Greyhound landed
Lewis Brisbois on the week's legal lambs list.
Read full article »
Podcast
Law360's The Term: The Gov't May Owe ACA Insurers Billions
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EFTA00032950


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=== Page 1 ===
Attn:
Questioned Documents Unit
FBI Laboratory
Lab #: 2020-01577 #2
Evidence: Packaging B1
2020-01577 #2
2020-01577 #2
:ROM: FBI NY ECU
Item 4 through
Item 5
26 Federal Plaza
NY, NY 10278
and
EFTA00032996

=== Page 2 ===
ENVELOPE
EMPTY
Official DocLab Instruction(s) - Revised 10-Apr-2014
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=== Page 1 ===
UNITED STATESATTORNEYS
Request, Authorization, and Order for Services of
Expert Witness, Litigative Consultant, or ADR Neutral
Contract/Purchase Order No.:
Date:
Part I- Request for Services
1. Requesting Official (Name & Title)
2. Signature of Requesting Official
3. Point of Contact (Name and Tel.)
4. Date of Request
8/30/2021
Telephone:
5. Preparer (Name & Tel.)
6. Originating Office (Name & Address)
7. Case Name, Court & Ct. Docket No.
8. DJ File No./USAO No.
U.S. Attorney's Office, SDNY
US v. Maxwell, 20 Cr. 330
2018R01618
9. Contractor (Name and Tel.)
10. Contractor Mailing Address
11. Contractor TIN or SSN (individual)
12. Contractor Specialty
Taylor Trial Consulting
Jury consulting services
Telephone:
13. Reason for Request (Place an "X" in the applicable Box in the Left Column)
13.a. Expert Testimony on Behalf of U.S.
13.b. Deposition Conducted by DOJ Attorney
13.c. Medical Examination of Plaintiff/Witness/Defendant in Contemplation of Testimony on Behalf of U.S.
13.d. Examination Under 18 USC 4241, Mental Competency to Stand Trial Only
13.e. Dual Purpose Psychiatric Examination (Time of Offense and Competency to Stand Trial) on the motion of:
13.f. ADR Neutral Services
X
13.g. Litigative Consultant Services
13.h. Other (explain below):
Attach the Statement of Work to this Form
14. Negotiated Contractor Rates, Estimated Expenses, and Performance Dates (Note: Expenses incurred must be supported by receipts)
Service/Expense
Performance Dates (From-To)
Hour/Day
Quantity
Rate
Total
14.a. Examine Case
-
Hour
$ 0.00
14.b. Prepare Testimony
-
Hour
$0.00
14.c. Court Testimony
-
Hour
$0.00
14.d. Deposition
-
Hour
$ 0.00
14.e. Litigative Consultant/Neutral
-
Hour
$ 0.00
14.f. Per Diem (if not part of fee)
Day
$ 0.00
14.g. Privately Owned Vehicle (NTE coach rate)
Mile
$ 0.00
14.h. Common Carrier Transportation Via GTA
14.i. Common Carrier Transportation Reimbursed
14.j. Miscellaneous
14.k. Total Estimated Expenses
$ 63,000.00
15. Submit Invoices & EFT Information to:
16. Payment will be made by: (Place an "X" in the applicable Box and fill-in if not JMD/Finance)
U.S. Attorney's Office, SDNY
X
Box 15
Budget & Fiscal Unit
Form USA-47 (Revised 5-2008)
Page 1 of 2
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=== Page 1 ===
From:
)"
To: Mariann Wang
Cc: Gloria Allred
Subject: RE: Another survivor
Date: Thu, 18 Mar 2021 15:46:13 +0000
Thanks very much.
Original Message
From: Mariann Wang
Sent: Thursday, March 18, 2021 9:05 AM
To:
Cc: Gloria Allred
Subject: Re: Another survivor
Sure, here you go:
Gloria,
Mariann,
Eric Hecker,
> On Mar 17, 2021, at 11:09 PM,
)
wrote:
>
>
That should work, thanks. Mind sending me the names and email addresses of participants, please?
V
>
Original Message
> From: Mariann Wang
> Sent: Wednesday, March 17, 2021 10:54 PM
> To:
)
> Cc: Gloria Allred
> Subject: Re: Another survivor
>
> Sure, how about April 2d at 12.30pm?
V
>> On Mar 17, 2021, at 4:02 PM,
)
<https://protect2.fireeye.com/v1/url?
k=19c9489f-465271d3-19ce6c7a-0cc47adca7cc-3b20306438cf72c9&q=1&e=22490b16-8769-4edf-89e3-
3533a30390df&u=https%3A%2F%2Furldefense.proofpoint.com%2Fv292Furl%3Fu3Dhtp-
40usdoj.gov%26d%3DDwIGaQ%26c%3DeuGZstcaTDIlvimEN8b7jXrwqOf-
v5A_CdpgnVfiMM%26r%3DD5E4Bj8gRz08EJSOhEOXHg%26m%3DjqlYct8JdaT-W5q4i-
N5aJFbPbaZ0jvBiRwZOdECfbg%26s%3Db1rLNAgLFL1YwQx7TzXEotwfEBLq70RMGqj1PDT23026e4
3D> wrote:
>> Hi Mariann,
>> Hope you're well too, thanks. April 1 is pretty full on my end now. Would April 2 work for an interview with
this survivor, please?
Thanks,
EFTA00031943

=== Page 2 ===
>>
Original Message
>>
From: Mariann Wang
>> Sent: Wednesday, March 17, 2021 8:48 AM
To:
>>
Cc: Gloria Allred
>> Subject: Another survivor
,
>> I hope you're well. We have another survivor who would like to share her information/what happened to her.
If you're willing/open, perhaps we could just add her to April 1st, or let us know what you prefer. She is
someone who was abused by Epstein on one occasion in 2004.
>>
Thank you,
>> Mariann
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=== Page 1 ===
From:
To:
)"
Subject: RE: Subpoenas Re
Date: Fri, 16 Aug 2019 17:28:04 +0000
Thanks again!
Original Message
From:
) [mailto:
Sent: Friday, August 16, 2019 1:13 PM
To:
i
)
)
Cc:
Subject: RE: Subpoenas Re
Subpoenas attached, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From:
Sent: Thursday, August 15, 2019 5:08 PM
To:
i
Cc:
Subject: Subpoenas Re
Please prepare and return to me subpoenas for Wells Fargo, CITI, MoneyGram, Western Union and Experian
regarding
I have attached the riders for the subpoenas. I will serve the subpoenas.
Additionally, please utilize the following text in the subpoenas:
If you have any questions, please contact Forensic Accountant
or Special Agent
Please forward the results in an electronic format to Special Agent
, Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
EFTA00032383

=== Page 2 ===
If you have any questions or comments, please contact me.
Thanks
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein forfeiture theory
Date: Wed, 04 Dec 2019 18:59:39 +0000
I'm late to this but that time works for me too, thanks.
From:
Sent: Wednesday, December 04, 2019 13:58
To:
Cc:
Subject: Re: Epstein forfeiture theory
I'm hobbled, so I can host on 3. Thanks!
Sent from my iPhone
On Dec 4, 2019, at 1:53 PM,
)
> wrote:
Sure, would you like us to come to one of your offices, or should I reserve a conference room?
From
Sent: Wednesday, December 4, 2019 1:44 PM
To:
is
i
Subject: RE: RE: Epstein forfeiture theory
Good here. Can someone send an invite?
From:
Sent: Wednesday, December 4, 2019 1:43 PM
To:
Subject: RE: RE: Epstein forfeiture theory
Same, thanks!
From:
Sent: Wednesday, December 4, 2019 1:33 PM
To:
^
Cc:
Subject: RE: RE: Epstein forfeiture theory
That's perfect for me, thanks.
EFTA00032856

=== Page 2 ===
From:
Sent: Wednesday, December 4, 2019 1:24 PM
To:
Cc:
Subject: RE: RE: Epstein forfeiture theory
Monday is pretty open. Maybe 2pm?
Co-Chief, Money Laundering and Transnational Criminal Enterprises Unit
Asset Forfeiture Coordinator
United States Attorney's Office
Southern District of New York
From:
Sent: Wednesday, December 4, 2019 1:08 PM
To:
Cc:
Subject: RE: Epstein forfeiture theory
Is there a time early next week that we might be able to meet with one or both of you to talk about forfeiture theories
for certain Epstein properties? I know that we've talked about this in some detail already, but currently counsel for the
Trustees of his estate are working on thinking about the value of the government's potential claims, in particular relating
to statute of limitations issues, so we want to make sure we have the best possible arguments to present to them. Sorry
for continuing to bother you on this, but we really appreciate the help!
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From
To
Subject: Re: good morning
Date: Mon, 06 Jul 2020 15:47:22 +0000
Thanks.
- I think I knew that
vere handling that.
- I'm supposed to make arrangements to speak with
really just to say goodbye), but I can discuss CIDs
with him too.
- Always happy to talk.
Sent from my iPhone
> On Jul 6, 2020, at 11:38 AM,
wrote:
V
V
(before she went out on leave) have been handling the trust-related issues.
V
V
V
> I will take advantage of your wisdom as much as possible during the next two weeks. FYI, I received an email
at the end of last week from
letting me know that he is now handling CIDs. (I have not sent him
any yet.)
V
>
Original Message
> From:
> Sent: Monday July 06 2020 10:42 AM
> To:
> Sub
>
>
Glad to hear that all is quiet.
>
>
Who from the Civil Division will be assigned to deal with Epstein trust-related matters?
V
V
>
> - You're kind to say so, but once you've given notice, it's better to leave sooner rather than later. Subject to
what
have to say, my tentative departure date is two weeks from today (July 20). I obviously would
be happy to discuss things Civil (or to review proposed CIDs) at any point until then.
V
> My weekend was quiet. Pretty uneventful. Not unlike most other days except that I pretty much stayed away
from email.
V
> Sent from my iPhone
V
>> On Jul 6, 2020, at 10:32 AM,
wrote:
>>
>> Thanks
All is quiet on my end. We are having a call with
oday at 1:15 to discuss Epstein
trust-related matters.
>>
EFTA00032045

=== Page 2 ===
>> I was thinking about you this morning and hoping that your departure date would not be too soon.
How was your weekend?
Original Message
From
Sent: Monday, July 06, 2020 10:24 AM
To:
Subject: good morning
>> Good morning. I hope that you had a nice weekend and were able to take a break from running(!). Any
news of note? None on my end. I'm hoping to speak with
today to sort out the logistics of my
departure. And more stuff along those lines.
>>
Sent from my iPhone
EFTA00032046


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=== Page 1 ===
Suicide Watch
1. Epstein #76318-054
Psych Observation
None
Thank you,
CONFIDENTIAL
SDNY_00009873
EFTA00034020


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
,
(USANYS) 6"
Subject: RE: call W SEC
Date: Thu, 08 Aug 2019 20:00:19 +0000
Okay, we can come to you.
From:
(USANYS)
Sent: Thursday, August 8, 2019 3:05 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS) 6
Subject: RE: call W SEC
We are on for 4;45
From:
(USANYS)
Sent: Thursday, August 8, 2019 2:04 PM
To:
(USANYS)
in
(USANYS)
Cc:
(USANYS) 6
Subject: RE: call W SEC
I think one or both of us free for the next hour or so, and then again after about 4:30.
From:
(USANYS)
Sent: Thursday, August 8, 2019 1:55 PM
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS) 6
Subject: call W SEC
PCers,
SEC called again with some questions on their Epstein inquiry. They mainly want to continue to avoid anything that would
be problematic for the criminal case. We thought it would be easiest if some group of the 4 of us got on a call with them.
Do one or both of you have some availability this afternoon?
Thanks,
EFTA00032489


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=== Page 1 ===
From:
Subject: FW: Jeffrey Epstein friend Ghislaine Maxwell under FBI investigation
Date: Fri, 27 Dec 2019 14:36:53 +0000
You're not the only one who noticed
Original Message
From:
Sent: Friday, December 27, 2019 9:36 AM
To:
Subject: Jeffrey Epstein friend Ghislaine Maxwell under FBI investigation
https://www.cnbc.com/2019/12/27/jefrey-epstein-friend-ghislaine-maxwell-under-fbi-investigation.hml
Sent from my iPhone
EFTA00032500


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=== Page 1 ===
From: Marc Fernich
To:
)"
Cc:
) [Contractor]"
(USANYS) [Contractor]"
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Mon, 08 Jul 2019 15:56:24 +0000
Received. Thanks.
Marc Fernich, Esq.
Sent from my iPhone
On Jul 8, 2019, at 10:53 AM,
)
wrote:
Marc,
Wanted to send this to you as well in case your co-counsel can't receive it in the Court. Please let me know if it would
be helpful to get a hard copy - I'm copying two of our paralegals who can bring you (or co-counsel) a copy; l'll be
unreachable for the next hour or so.
thank you,
From:
Sent: Monday, July 08, 2019 10:43
To:
Cc:
i
; 'Martin Weinberg'
>; 'rweingarten@steptoe.com
is
)
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Pitman:
In advance of the expected bail argument in the above-captioned case, in connection with the presentment and
arraignment referred by Judge Berman, attached please find a memorandum from the government on the issue of
detention. Defense counsel is copied, as is the chambers of Judge Berman at their request.
Thank you,
EFTA00032972

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
<U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum.pdf>
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=== Page 1 ===
Psych Observation 7/24-30/19 (I/M companion utilized)
CONFIDENTIAL
SDNY_00009598
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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
Subject: RE: [EXTERNAL] RE: United States V. Ghislaine Maxwell
Date: Wed, 20 Oct 2021 18:03:03 +0000
Attachments: 2021.10.19_Order_re_October_21_Teleconference.pdf
Thanks very much,
You and
can access tomorrow's conference by calling
and dialing access
code
Per the attached order from the Court, to the extent others would like to access the conference, they
should use the public dial-in provided in the Court's order
(
and using access code
).
Thanks,
From:
Sent: Wednesday, October 20, 2021 11:11 AM
To:
(USANYS)
Cc:
Subject: Re: [EXTERNAL] RE: United States V. Ghislaine Maxwell
Yes my apologies.
will call from her cell
I will call from
Get Outlook for iOS
From:
(USANYS)
Sent: Wednesday, October 20, 2021 9:06:32 AM
To:
Cc:
Subject: Re: [EXTERNAL] RE: United States V. Ghislaine Maxwell
,
can you please send along the phone numbers that you and
will be using to call into the conference? We
need to provide those to the court. Thanks very much.
On Oct 18, 2021, at 5:39 PM,
(USANYS)
> wrote:
Thanks,
Can you please let us know the phone numbers from which you both will be calling for the conference
this week? We will get back to you on your question about the November 1 conference.
Thanks for reaching out about additional meeting times. I will circle back to you with some dates that work for us to
meet with
Thanks so much,
On Oct 18, 2021, at 3:34 PM,
wrote:
EFTA00032799

=== Page 2 ===
Hello
- both myself and
would like to be on by phone for the October 21st hearing.
will not be able to
be in NYC on November 1st and she is wondering if there will be a phone option for that hearing as well?
also asked if you could give her some dates for additional prep times so she can be ready for the trial. I told her
you are of course very busy right now but I am sure will work in some times to meet.
Thank you,
Partner
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:07 PM
To:
Cc:
Subject: United States V. Ghislaine Maxwell
I hope all is well. There are two upcoming court appearances in this case: a teleconference on October 21 at 12 pm
EST and an in-person pretrial conference on November 1 at 11 am. Can you please let us know tomorrow if
plans to listen to the October 21 teleconference? Can you also please let us know if she plans to attend the November
1 in-person conference?
I'm happy to give you a call tomorrow if there's anything you would like to discuss.
Thanks very much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic
message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution,
copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the
sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attomey work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00032800


c1: EFTA00032748
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032748.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Maxwell - RTC
Date: Fri, 15 Oct 2021 15:45:30 +0000
Attachments: Maxwell_RTC_v11.docx
Hi guys,
I'm pretty slammed as we're in the thick of a period where we have 23 briefs due in the span of 30 days, plus the usual
other appeals stuff going on. I've also never been asked to review an entire RTC like this (neither has Sarah, for what it's
worth), so I don't think you'll get much value-add anyway. I want to be helpful, of course, but is there something discrete
and tricky you need help with on these?
Thanks,
From:
Sent: Monday, October 11, 2021 8:14 PM
To:
Cc:
Subject: RE: Maxwell - RTC
Hi
We just wanted to check in and see if you think you'll have a chance to look at the Maxwell RTC before we send it to the
defense. We're planning to do that on October 20, and if you have time to look at this before then, we'd really like to
incorporate your comments.
Thanks!
From:
Sent: Thursday, September 30, 2021 10:50 AM
To:
Cc:
Subject: Maxwell - RTC
Hi
I hope all's well! Attached is a draft of our RTC in the Maxwell case. If you have time to look at it, we'd love any
comments you might have.
In terms of timing, we have to file a joint proposed RTC on October 27, so we are thinking of sending this to the defense a
week or so before that.
EFTA00032748

=== Page 2 ===
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00032749


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032329.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
]"
To:
)"
Subject: scan
Date: Thu, 24 Oct 2019 17:45:36 +0000
Attachments: Epstein_Victims_Attendees,_Agenda.pdf
Paralegal Specialist
U.S. Attorney's Office I
SDNY
Office:
Cell:
EFTA00032329


c1: EFTA00033843
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033843.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Bureau of Prisons
Health Services
Vision Screens
Reg #: 76318-054
Inmate Name: EPSTEIN, JEFFREY EDWARD
Vision Screen on 07/09/2019 12:52
Blindness:
Distance Vision: OD: 20/100
OS: 20/70
OU:
Near Vision:
OD:
OS:
OU:
With Corrective
Distance Vision: OD:
OS:
OU:
Near Vision:
OD:
OS:
OU:
Present Glasses - Distance
Refraction - Distance
Sphere
Cylinder
Axis
Add
Sphere
Cylinder
Axis
Add
R:
R:
L:
L:
Color Test:
Tonometry: R:
L:
Comments: Needs evaluation with optometrist.
Orig Entered: 07/09/2019 12:54 EST
MLP
Generated 08/10/2019 11:02 by
Bureau of Prisons - NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009458
EFTA00033843

=== Page 2 ===
Bureau of Prisons
Health Services
Immunizations
Begin Date: 07/07/2019
End Date:
08/10/2019
Reg #:
76318-054
Inmate Name: EPSTEIN, JEFFREY EDWARD
Immunization
Immunization Date
Administered
Location
Dosage Drug Mfg.
Lot #
Exp Date
Hepatitis A and B (TwinRx)
History Unknown
Orig Entered: 07/09/2019 12:51 EST
MLP
Measles/Mumps/Rubella Series
History Unknown
Orig Entered: 07/09/2019 12:51 EST
MLP
Smallpox Series
History Unknown
Orig Entered: 07/09/2019 12:51 EST
MLP
Tetanus
History Unknown
Orig Entered: 07/09/2019 12:51 EST
MLP
Varicella Series
History Unknown
Orig Entered: 07/09/2019 12:51 EST
MLP
Total: 5
Generated 08/10/2019 11:02 by
RN/IOP/IDC
Bureau of Prisons NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009459
EFTA00033844

=== Page 3 ===
Bureau of Prisons
Health Services
Medical Duty Status
Reg #: 76318-054
Inmate Name: EPSTEIN, JEFFREY EDWARD
Housing Status
confined to the living quarters except
meals
pill line
treatments
Exp. Date:
on complete bed rest:
bathroom privileges only
Exp. Date:
X cell:
cell on first floor single cell X lower bunk airborne infection isolation
Exp. Date: 10/09/2019
other:
Exp. Date:
Physical Limitation/Restriction
all sports
Exp. Date:
weightlifting:
upper body
lower body
Exp. Date:
cardiovascular exercise: running jogging walking softball
Exp. Date:
football basketball handball stationary equipment
other:
Exp. Date:
May have the following equipment in his / her possession:
Equipment
Start Date
End Date
Return Date
C-Pap
07/30/2019
PHILIPS RESPIRONICS SYSTEM ONE CPAP MACHINE.
SERIAL #: P11312813B1ED.
Work Restriction / Limitation:
Cleared for Food Service: Yes
X No Restrictions
Comments: N/A
07/30/2019
Health Services Staff
Date
Inmate Name:
EPSTEIN, JEFFREY EDWARD
Reg #:
76318-054
Quarters:
Z04
ALL EXPIRATION DATES ARE AT 24:00
Generated 08/10/2019 11:02 by
Bureau of Prisons - NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009460
EFTA00033845

=== Page 4 ===
Bureau of Prisons
Health Services
Medical Duty Status
Reg #: 76318-054
Inmate Name: EPSTEIN, JEFFREY EDWARD
Housing Status
confined to the living quarters except
meals
pill line
treatments
Exp. Date:
on complete bed rest:
bathroom privileges only
Exp. Date:
X cell:
cell on first floor single cell X lower bunk airborne infection isolation
Exp. Date: 10/09/2019
other:
Exp. Date:
Physical Limitation/Restriction
all sports
Exp. Date:
weightlifting:
upper body
lower body
Exp. Date:
cardiovascular exercise: running jogging walking softball
Exp. Date:
football basketball handball stationary equipment
other:
Exp. Date:
May have the following equipment in his / her possession:
Work Restriction / Limitation:
Cleared for Food Service: Yes
X No Restrictions
Comments: N/A
MLP
07/09/2019
Health Services Staff
Date
Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-054 Quarters: Z04
ALL EXPIRATION DATES ARE AT 24:00
Generated 08/10/2019 11:02 by
Bureau of Prisons - NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009461
EFTA00033846

=== Page 5 ===
Bureau of Prisons
Health Services
Medication Summary
Historical
Complex: NYM--NEW YORK MCC
Begin Date: 07/07/2019
End Date: 08/10/2019
Inmate: EPSTEIN, JEFFREY EDWARD
Reg #:
76318-054
Quarter: Z04-206LAD
Medications listed reflect prescribed medications from the begin date to end date on this report.
Allergies:
Denied
Active Prescriptions
Bisacodyl E.C. 5 MG TAB
Take one tablet (5 MG) by mouth at bedtime AS NEEDED for 10 days
Rx#: 121757-NYM
Doctor:
MLP
Start: 07/09/19
Exp: 07/19/19
D/C: 07/12/19
Pharmacy Dispensings: 10 TAB in 32 days
Docusate Sodium 100 MG Cap
Take one capsule (100 MG) by mouth twice daily for 30 days
Rx#: 121823-NYM
Doctor:
Start: 07/12/19
Exp: 08/11/19
Pharmacy Dispensings: 60 CAP in 29 days
Docusate Sodium 100 MG Cap
Take one capsule (100 MG) twice daily by mouth with plenty of water
Rx#: 122084-NYM
Doctor:
Start: 07/26/19
Exp: 01/22/20
Pharmacy Dispensings: 30 CAP in 15 days
Milk of Magnesia Susp (OTC) (473ML) 400MG/5ML
shake well take 2 tablespoonful twice daily by mouth
Rx#: 121835-NYM
Doctor:
Start: 07/12/19
Exp: 07/14/19
Pharmacy Dispensings: 473 ML in 29 days
Milk of Magnesia Susp (OTC) (473ML) 400MG/5ML
shake well take 10ml by mouth twice daily AS NEEDED
Rx#: 122150-NYM
Doctor:
Start: 07/30/19
Exp: 10/28/19
Pharmacy Dispensings: 473 ML in 11 days
methylPREDNISolone 4 MG Tab (21 count Pack)
Take the tablet by mouth as directed
Rx#: 121836-NYM
Doctor:
Start: 07/12/19
Exp: 07/18/19
Pharmacy Dispensings: 21 tab in 29 days
methylPREDNISolone 4 MG Tab (21 count Pack)
Take the tablet by mouth as directed
Rx#: 122149-NYM
Doctor:
Start: 07/30/19
Exp: 08/05/19
Pharmacy Dispensings: 21 tab in 11 days
Generated 08/10/2019 11:02 by
Bureau of Prisons - NYM
Page 1 of 2
CONFIDENTIAL
SDNY_00009462
EFTA00033847

=== Page 6 ===
Complex: NYM--NEW YORK MCC
Begin Date: 07/07/2019
End Date: 08/10/2019
Inmate: EPSTEIN, JEFFREY EDWARD
Reg #:
76318-054
Quarter: Z04-206LAD
Active Prescriptions
Omega 3 (Vascepa) 1 GM Capsule
Take two capsules (2 GM) twice daily by mouth with food
Rx#: 121885-NYM
Doctor:
Start: 07/17/19
Exp: 01/13/20
Pharmacy Dispensings: 180 Cap in 24 days
Insulin Reg (10 ML) 100 UNITS/ML Inj
Inject regular insulin subcutaneously per sliding scale: twice daily ***pill line*** for 7 days ***pill line***
Rx#: 122148-NYM
Doctor:
Start: 07/30/19
Exp: 08/06/19
D/C: 07/31/19
Pharmacy Dispensings: 0 ML in 11 days
Insulin Reg (10 ML) 100 UNITS/ML Inj
Inject regular insulin subcutaneously per sliding scale: each morning for 7 days ***pill line*** ***pill line***
Rx#: 122160-NYM
Doctor:
Start: 07/31/19
Exp: 08/07/19
Pharmacy Dispensings: 0 ML in 10 days
Generated 08/10/2019 11:02 by
Bureau of Prisons - NYM
Page 2 of 2
CONFIDENTIAL
SDNY_00009463
EFTA00033848

=== Page 7 ===
Bureau of Prisons
Health Services
Dental Health History Screen
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex: M Race: WHITE
Facility: NYM
Encounter Date: 07/26/2019 07:54
Provider:
DDS Unit: H01
ASSESSMENTS:
Health Problems as of Dental Health History Encounter date: 07/26/2019 07:54
Health Problems
Health Problem
Status
Hyperlipidemia, unspecified
Current
HYPERTRIGLYCERIDEMIA
Sleep apnea
Current
Constipation, unspecified
Current
Low back pain
Current
Neuralgia and neuritis, unspecified
Current
No Diagnosis
Current
Injury, unspecified
Current
R/O self inflicted injuries.
Medical History as of Dental Health History Encounter date: 07/26/2019 07:54
Medical History:
Allergies:
Denied
Seizures:
Denied
Diabetes:
Denied
Cardiovascular:
Denied
CVA:
Denied
Hypertension:
Denied
Respiratory:
Denied
Sickle Cell Anemia:
Denied
Carcinoma/Lymphoma:
Denied
HIV History:
When Tested:
2019
Test Result:
Negative
When Diagnosed AIDS:
Last CD4:
Comments:
Hepatitis:
Denied
Generated 07/26/2019 07:59 by
DDS
Bureau of Prisons - NYM
Page 1 of 3
CONFIDENTIAL
SDNY_00009464
EFTA00033849

=== Page 8 ===
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex: M Race: WHITE
Facility: NYM
Encounter Date: 07/26/2019 07:54
Provider:
DDS
Unit:
H01
Other Infectious Diseases:
Syphilis:
No
Syphilis Last Treatment:
N/A
Genital Warts:
No
Chlamydia:
Yes
Gonorrhea:
No
Herpes:
No
Chicken Pox:
Yes
Other:
No
Comments: Chlamydia in 2015, treated
Chicken pox in childhood
Other Health Issues:
Other Medical Conditions And Treatment: sleep apnea
Current Medical Conditions:
Other Current Treatments:
Pregnant: N/A
Dental Observations as of Dental Health History Encounter date: 07/26/2019 07:54
History:
Alcohol:
No
Methamphetamine:
No
Tobacco products:
No
Other drugs:
No
Sensitive teeth:
No
Bleeding gums:
Yes
Food impaction:
Yes
Pain around ear:
No
Toothache:
No
Wear partial dentures:
No
Unusual sounds while eating:
No
Snoring:
Yes
Blisters on lips or mouth:
No
Clenching or grinding:
Yes
Swelling or lumps in mouth/throat:
No
Burning tongue:
No
Bad breath:
No
Decayed teeth:
No
Loose teeth:
No
Wear dentures:
No
None:
No
Comments:
Generated 07/26/2019 07:59 by
DDS
Bureau of Prisons - NYM
Page 2 of 3
CONFIDENTIAL
SDNY_00009465
EFTA00033850

=== Page 9 ===
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex: M Race: WHITE
Facility: NYM
Encounter Date: 07/26/2019 07:54
Provider:
DDS
Unit:
H01
Cardiac Condition Requiring Prophylaxis: No
Prosthetic joint(s):
No
Radiation history of head or neck:
No
Excessive bleeding:
No
Bisphosphonates:
No
Comments:
Medications as of Dental Health History Encounter date:
07/26/2019 07:54
Medications:
Docusate Sodium 100 MG Cap Exp: 08/11/2019 SIG: Take one capsule (100 MG) by mouth twice daily for 30 days
Omega 3 (Vascepa) 1 GM Capsule Exp: 01/13/2020 SIG: Take two capsules (2 GM) twice daily by mouth with food
OTCs: Listing of all known OTCs this inmate is currently taking.
Instructed inmate how to obtain medical, dental, and mental health care.
Copay Required: No
Cosign Required: No
Telephone/Verbal Order: No
Completed by
DDS on 07/26/2019 07:59
Generated 07/26/2019 07:59 by
DDS
Bureau of Prisons - NYM
Page 3 of 3
CONFIDENTIAL
SDNY_00009466
EFTA00033851

=== Page 10 ===
Bureau of Prisons
Health Services
Dental A&O Exam
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #: 76318-054
Date of Birth: 01/20/1953
Sex: M
Race: WHITE
Facility: NYM
Encounter Date: 07/26/2019 07:47
Provider:
DDS
Unit:
H01
Reviewed Health Status: Yes
Occlusion: Class I
Oral Hygiene: Fair
CPITN:
323
323
Hard and soft tissue examination performed and documented on BP618 form: Yes
Head & Neck/Soft Tissue within normal limits?
No
Comments:
moderate to advanced upper posterior gingival recession
Decayed: Missing:
Filled:
0
1
14
Comments:
Lower anterior crowding
Approved for hygiene appointment and radiographs:
Yes
Instructed inmate how to obtain routine and emergency dental care. Oral hygiene instructions given: Yes
Dental A&O Screening Exam findings entered on EPSTEIN, JEFFREY EDWARD by
DDS on
07/26/2019 07:47.
Generated 07/26/2019 08:00 by
DDS
Bureau of Prisons - NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009467
EFTA00033852

=== Page 11 ===
Bureau of Prisons
Health Services
Dental Soap/Admin Encounter
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #:
76318-054
Date of Birth: 01/20/1953
Sex:
M
Race: WHITE
Facility:
NYM
Encounter Date: 07/18/2019 13:48
Provider:
Dental Asst
Unit:
Z05
Screening encounter at Dental Clinic.
Reason Not Done: Unavailable
Comments: Patient has had several call outs for his Dental A & O screening but has not been escorted to the dental clinic.
Cosign Required: No
Completed by
Dental Asst on 07/19/2019 13:49.
Generated 07/19/2019 13:49 by
Dental
Bureau of Prisons NYM
Page 1 of 1
CONFIDENTIAL
SDNY_00009468
EFTA00033853

=== Page 12 ===
Federal
U.S. Medical Center for Federal Prisons
Bureau of
1900 W. Sunshine Street
Prisons
Springfield, MO 65807
417-874-1621
*** Sensitive But Unclassified ***
Name EPSTEIN, JEFFREY
Facility MCC New York
Collected 07/09/2019 13:34
Reg # 76318-054
Order Unit E06-547U
Received 07/10/2019 10:44
DOB 01/20/1953
Provider
MD
Reported 07/10/2019 14:46
Sex
M
LIS ID 188191004
CHEMISTRY
Sodium
137
137-148
mmol/L
Potassium
4.7
3.5-5.0
mmol/L
Chloride
99
99-114
mmol/L
CO2
27
22-30
mmol/L
BUN
17
7-22
mg/dL
Creatinine
1.05
0.66-1.25
mg/dL
eGFR (IDMS)
>60
GFR units measured as mL/min/1.73 m^2. If African American multiply by 1.210.
A calculated GFR <60 suggests chronic kidney disease if found over a 3 month period.
Calcium
9.8
8.5-10.9
mg/dL
Glucose
102
70-110
mg/dL
AST
H
57
11-55
U/L
ALT
62
11-66
U/L
Alkaline Phosphatase
64
41-133
U/L
Bilirubin, Total
1.1
0.2-1.3
mg/dL
Total Protein
7.3
6.0-8.2
g/dL
Albumin
4.4
3.6-5.1
g/dL
Globulin
2.9
2.0-3.7
g/dL
Alb/Glob Ratio
1.50
1.00-2.30
Anion Gap
10.2
9.0-19.0
BUN/Creat Ratio
16.1
5.0-30.0
Cholesterol
H
216
<200
mg/dL
Triglycerides
H
413
10-150
mg/dL
Calculation of LDL is not appropriate for samples with a triglyceride greater than 400 mg/dL. Therefore the LDL is not calculated.
HDL Cholesterol
L
31
40-60
mg/dL
Chol/HDL Ratio
H
6.9
0.0-4.0
HEMATOLOGY
WBC
7.6
4.3-11.1
K/uL
NRBC%
0.0
%
RBC
5.42
4.46-5.78
M/uL
Hemoglobin
15.6
13.6-17.6
g/dL
Hematocrit
47.8
40.2-51.4
%
MCV
88.2
82.5-96.5
fL
MCH
28.8
27.1-34.9
pg
MCHC
L
32.6
33.0-37.0
g/dL
RDW-CV
12.8
12.0-14.0
%
Platelet
338
130-374
K/uL
FLAG LEGEND L=Low L!=Low Critical H=High H!=High Critical A=Abnormal A! =Abnormal Critical
Page 1 of 3
CONFIDENTIAL
SDNY_00009469
EFTA00033854

=== Page 13 ===
Federal
U.S. Medical Center for Federal Prisons
Bureau of
1900 W. Sunshine Street
Prisons
Springfield, MO 65807
417-874-1621
*** Sensitive But Unclassified ***
Name EPSTEIN, JEFFREY
Facility MCC New York
Collected 07/09/2019 13:34
Reg # 76318-054
Order Unit E06-547U
Received 07/10/2019 10:44
DOB 01/20/1953
Provider
MD
Reported 07/10/2019 14:46
Sex M
LIS ID 188191004
HEMATOLOGY
MPV
10.4
6.9-10.5
fL
Neutrophils %
58.7
%
Therapeutic decision making should be based on absolute values, rather than percentages
Lymphocytes %
25.0
%
Monocytes %
11.1
%
Eosinophils %
4.1
%
Basophils %
0.8
%
Immature Granulocytes %
0.3
0.0-5.0
%
Neutrophils #
4.4
1.9-6.7
K/uL
Lymphocytes #
1.9
1.3-3.7
K/uL
Monocytes #
0.8
0.3-1.1
K/uL
Eosinophils #
0.3
0.0-0.5
K/uL
Basophils #
0.1
0.0-0.1
K/uL
Immature Granulocytes #
0.02
0.00-0.50
10^3/uL
HEMOGLOBIN A1C
Hemoglobin A1C
H
6.3
<5.7
%
5.7 - 6.4 Increased Risk
> 6.4 Diabetes
SEROLOGY
RPR
Non-Reactive
Non-Reactive
Results may be affected in patients with severely advanced immunosuppression.
FLAG LEGEND L=Low L!=Low Critical H=High H!=High Critical A=Abnormal A! =Abnormal Critical
Page 2 of 3
CONFIDENTIAL
SDNY_00009470
EFTA00033855

=== Page 14 ===
Federal
U.S. Medical Center for Federal Prisons
Bureau of
1900 W. Sunshine Street
Prisons
Springfield, MO 65807
417-874-1621
*** Sensitive But Unclassified ***
Name EPSTEIN, JEFFREY
Facility MCC New York
Collected 07/09/2019 13:34
Reg # 76318-054
Order Unit E06-547U
Received 07/10/2019 10:44
DOB 01/20/1953
Provider
MD
Reported 07/10/2019 14:46
Sex M
LIS ID 188191004
HIV
HIV 1/2
Negative
Negative
Screening test- - See confirmatory testing for Reactive results
FLAG LEGEND L=Low L!=Low Critical H=High H!=High Critical A=Abnormal A! =Abnormal Critical
Page 3 of 3
CONFIDENTIAL
SDNY_00009471
EFTA00033856

=== Page 15 ===
Bureau of Prisons
Health Services
Cosign/Review
Inmate Name: EPSTEIN, JEFFREY EDWARD
Reg #:
76318-054
Date of Birth: 01/20/1953
Sex:
M
Race:
WHITE
Encounter Date: 07/10/2019 16:58
Provider: Lab Result Receive
Facility: NYM
Cosigned by
on 07/14/2019 18:12.
Bureau of Prisons - NYM
CONFIDENTIAL
SDNY_00009472
EFTA00033857

=== Page 16 ===
BP-S358.060
MEDICAL TREATMENT REFUSAL
CDFRM
SEP 05
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
7-24-2019
Date
I, JEFFREY EPSTEIN
76318-054 , refuse treatment recommended by the Federal
Bureau of Prisons Medical staff for the following condition(s):
DESCRIBE CONDITION IN LAYMAN'S TERMINOLOGY:
EYE DOCTOR EVALUATION.
The following treatment(s) was/were recommended:
EYE DOCTOR EVALUATION.
Federal Bureau of Prisons Medical staff members have carefully explained to me that the following
possible consequences and/or complications may result because of my refusal to accept treatment:
INABILITY TO DIAGNOSE CURRENT OPTHALMOLOGIC DISEASES.
I understand the possible consequences and/or complications, listed above, and still refuse
recommended treatment. I hereby assume all responsibility for my physical and/or mental condition, and
release the Bureau of Prisons and its employees from any and all liability for respecting and following my
tions.
7-24-2019
Counseled by
Date
Date
07/14/19
Signature of Witness
Date
NYM--NEW YORK MCC
CONFIDENTIAL
SDNY_00009473
EFTA00033858

=== Page 17 ===
BP-A0618
A&O DENTAL EXAMINATION
JUN 16
(Initial Clinical Dental Findings)
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
Occlusion:
Oral Hygiene:
Good
Fair
Poor
CPITN:
3
2
3
3
2
3
Head & Neck / Soft Tissue:
RIGHT
1 2 3 4 5 6 7 B 9 10 11 12 13 14. 15 16
32 31 30 29 28 27 26 25 24 23 22 21 20 19 18 17
LEFT
Gold
Classification:
D: 0
M:
I
CLI
F: 14
Pain Scale:
/10
Dental Prostheses at Intake:
Yes
No
mod Comments: to moderage advanced singival
Type:
recession observed.
Age:
Condition:
Lower anter crowding observed
Intra-oral Photos Taken:
Radiographs Taken: (Document findings on A&O encounter)
Yes
Yes
No
No
Instructed how to obtain urgent and non-urgent dental care:
Yes:
No:
Treatment Priorities:
None:
Non-urgent:
Urgent: Referred to Sick Call:
non-urgent
Radiographs authorized:
Prophylaxis authorized:
Yes
No
PAs:
(Approval valid 18 months from examination date)
BWs:
Panorex:
Patient Name:
Dentist Signature:
Register Number: Jeffrey Institution: E
Epstein,
DDS
Date:
Signature Block/Stamp:
76318-054
MCC NEW YORK
7-26-19.
DDS.
Chief Dental Officer
MCC New York
PDF
Prescribed by P6400
Replaces BP-A0618 of JUN 10
CONFIDENTIAL
SDNY_00009474
EFTA00033859


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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Thursday, July 11, 2019
Beginning Count: 794
SHU: 74/5
Daily Sensitive Information:
M/W
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
794
74/5
Operations Lieutenant. The fire alarm and sprinkler system are
operational. PREA announcement conducted via the Institution
Public Address System and/or Radio. Restraint Equipment Cage
inventory conducted. All equipment accounted for. Metal Detector
checks conducted. All operative w/the exception of Rear
Gate/Facilities/R&D. Roof Check completed. All secure. Temporary
Chit Inventory: #1:2; #2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0
12:00 AM
Institution Count in progress
12:00 AM
NYPD Phone Check #2668
12:07 AM
Body Alarm testing in progress
12:26 AM
Body Alarm testing completed
12:30 AM
Watch Calls cont.
12:43 AM
Good Verbal count announced
12:46 AM
Clear Institution count announced
794
74/5
3:00 AM
Institution Count in progress
3:26 AM
Good Verbal count announced
3:30 AM
Clear Institution count announced
794
74/5
5:00 AM
Institution Count in progress
5:26 AM
Good Verbal count announced
5:39 AM
Clear Institution count announced
794
74/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
794
74/5
STG International Terrorist phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 794; SHU: 74; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
SDNY_00008185
EFTA00033431

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W Thursday, July 11, 2019
Beginning Count: 794
SHU: 74/5
D/W
Daily Sensitive Information:
.
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
794
74/5
Lieutenant. The fire alarm and sprinkler system are operational.
Unable to conduct PREA announcement over the Institution Public
Address System, due to, system malfunction. Restraint Equipment
Cage inventory conducted. All equipment accounted for. Metal
Detector checks conducted. All operative w/the exception of Rear
Gate. Roof Check completed. All secure. Temporary Chit Inventory:
#1:0; #2:5; #3:5; #4:6; #5:6; #6:5; Hosp:0
Daily Hand Stamp :GPKJ/LEFT HAND
8:00 AM
NYPD Phone Check #2654
8:125AM
Body Alarm Test Initiated
8:30 AM
AM Census Count Conducted
8:42 AM
Body Alarm Testing Complete
8:43 AM
Triple Deuce Testing Begin
9:30 AM
Triple Deuce Testing Complete
9:31 AM
-3 I/M Barcliff #76298-054, Bryant #72166-054, Maquilon #76315-054
791
73/5
9:32 AM
I/M Siddiqui #85797-053 out to L-Hosp w/bop staff
790
73/5
11:00 AM
Mainline feeding in progress
12:30 PM
PM Census Count Conducted
790
73/5
1:00 PM
2 I/M to ZA Grayson #70887-054, Perez #78346-054
790
75/5
2:00 PM
I/M Siddiqui #85797-053 return from L-Hosp
791
75/5
3:15 PM
I/M Vanier #86408-054, from IN to Special Housing
791
75/5
3:45 PM
Institution lockdown in progress for count.
4:00 PM
Relieved of duties by Lt.
as E/W Operations Lieutenant.
791
75/5
Visitation: 9 North
Inmates
Adults
Children
Total
15
22
6
43
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored: 0
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Grayson
70887-054
SIS INVESTIGATION
IN
1:00 PM
YES
Perez
78346-054
1:00 PM
YES
Vanier
86408-054
307 AND 321
IN
3:15 PM
YES
Ops Lt
Ending Count: 791; SHU: 75; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
SDNY_00008186
EFTA00033432

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHU:
SHIFT-DAY-DATE: E/W Thursday, July 11, 2019
Beginning Count: 791
76/5
Daily Sensitive Information.
E/W
I/M Cherry #76218-054 at local Hosp w/USMS Guards.
.
I/M Burnett #76254-054 at local Hosp w/USMS Guards.
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch
Operations Lieutenant. The fire alarm and sprinkler system are
operational. Unable to conduct PREA announcement over the
4:00 PM
Institution Public Address System, due to, system malfunction.
791
76/5
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:00 PM
NYPD Phone Check #1749
4:19 PM
Body Alarm testing in progress.
4:35 PM
Body alarm testing completed.
4:43 PM
Good verbal announced
4:47 PM
Clear institutional count.
791
76/5
6:00 PM
Watch call in progress
6:30 PM
Unit 9N locked down
19:50 PM
+10; I/M Galvez-Chimbo #76320-054, Hargrove #87014-054, Jiminez-
Castillo #76319-054, Jones #87016-054, Saasia #70704-054,
801
76/5
Shokralla #76323-054, Smith #76322-054, Vera-Velez #76321-054,
Vizzari #58614-054, and Williams #06600-052
8:15 PM
Trash run commenced.
8:50 PM
Trash run complete.
10:00 PM
Institutional count in progress.
10:22 PM
Good verbal count announced.
10:28 PM
Clear institutional count announced.
801
76/5
10:47 PM
I/M Vizzari #58614-054 to Psych Obs/Detox (Duty Psych notified)
12:00 AM
Relieved of duties by Lt
as M/W Operations Lieutenant.
801
76/5
VISITING: GN
INMATES
ADULTS
CHILDREN
TOTAL
19
23
06
48
STG/High Alert phone calls monitored: 0
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Ops. Lt.
Ending Count: 791 ; SHU: 76; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 02; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
SDNY_00008187
EFTA00033433

=== Page 4 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SDNY_00008188
EFTA0003343


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=== Page 1 ===
To:
From:
Sent:
Mon 8/12/2019 7:30:31 PM
Subject: SW Chronological Log 7/23-24/19 re: Epstein, Jeffrey Edward, Reg. No. 73618-054
TEXT.htm
2019 08 12 15 10 43.pdf
I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M
companion was utilized).
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009583
EFTA00033892


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=== Page 1 ===
From:
(USANYS)"
To: "Strauss, Audrey (USANYS)"
Subject: RE: Do we have transcript of hearing?
Date: Thu, 29 Aug 2019 21:09:57 +0000
Attachments: J8RpEPSf.pdf
Attached,
Original Message
From: Strauss, Audrey (USANYS)
Sent: Thursday, August 29, 2019 5:09 PM
To:
(USANYS)
Subject: Re: Do we have transcript of hearing?
IIf you send transcript now I will get that sent along and then call you.
Sent from my iPhone
> On Aug 29, 2019, at 5:07 PM,
(USANYS)
wrote:
Yes, will send. And I'm ready to do updates now if you're free. Am at my desk.
V V V V V V V V
Original Message
> From: Strauss, Audrey (USANYS)
> Sent: Thursday, August 29, 2019 5:05 PM
> To:
(USANYS)
Subject: Do we have transcript of hearing?
is asking for it.
> Sent from my iPhone
EFTA00032975


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Case
Date: Fri, 06 Sep 2019 18:12:55 +0000
Understood, thanks.
From:
Sent: Friday, September 6, 2019 12:58 PM
To:
Cc:
Subject: RE: Epstein Case
Thanks for letting me know. Monday should be ok, but I'm reluctant to let this spill over much later, since we do have the
pending request. I'm sure you understand.
Office of Chief Medical Examiner
New York, NY 10016
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is prohibited.
If you have received this communication in error, please notify us immediately by telephone or reply e-mail and permanently delete it and
any copies from your system files.
From:
Sent: Friday, September 06, 2019 12:56 PM
To:
Cc:
Subject: Re: Epstein Case
Hi
the review is taking a little longer here, so we will get you our redactions on Monday. Please let us know if
this poses any issues. Thank you.
On Sep 3, 2019, at 4:29 PM,
wrote:
Great, l'll give you a call at 2:45 tomorrow. Thanks.
From:
Sent: Tuesday, September 3, 2019 4:24 PM
To:
Subject: RE: Epstein Case
Tomorrow between 2-3 or after about 4:30, or Thursday after 2:30; either is fine with me.
Thanks!
EFTA00032423

=== Page 2 ===
Office of Chief Medical Examiner
New York, NY 10016
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is
prohibited. If you have received this communication in error, please notify us immediately by telephone or reply e-mail and
permanently delete it and any copies from your system files.
From:
Sent: Tuesday, September 03, 2019 4:21 PM
To:
Cc:
Subject: RE: Epstein Case
Hi
We will work on providing that list. Yes, I'm available tomorrow after 2 or Thursday after 2- what works for you?
Thanks.
From:
Sent: Tuesday, September 3, 2019 2:26 PM
To:
Cc:
Subject: RE: Epstein Case
I have now had the opportunity to discuss this request with both
and our
and I
am renewing my request that you provide a list of the specific documents and other materials that you are requesting
the OCME not disclose. Additionally, I would appreciate the opportunity to speak with you briefly concerning the
document that you have requested that OCME destroy, and that OCME has deactivated in the manner that I described
to you last week. Please let me know when would be convenient for you; thanks.
Office of Chief Medical Examiner
New York, NY 10016
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is
prohibited. If you have received this communication in error, please notify us immediately by telephone or reply e-mail and
permanently delete it and any copies from your system files.
From:
Sent: Wednesday, August 28, 2019 10:28 AM
To:
Cc:
Subject: Epstein Case
EFTA00032424

=== Page 3 ===
Hi
Per our discussion, please see attached.
We are also requesting that OCME destroy its copy of the draft interview report, dated August 12, 2019, relating to the
FBI's interview of
Please let us know if you have any questions. Thank you.
Assistant United States Attorney
Southern District of New York
EFTA00032425


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=== Page 1 ===
From:
)"
To:
)"
Subject: Please make binder this morning?
Date: Mon, 12 Aug 2019 11:42:48 +0000
Attachments: Combined_Epstein_Med_Records.pdf; 30_MINUTE_ROUNDS_8-8-19.pdf;
30_MINUTE_ROUNDS_8-9-19.pdf_30_MINUTE_ROUNDS_8-10-19_2pdf;
30_MINUTE_ROUNDS_8-10-19.pdf 30_MINUTE_ROUNDS_8-7-19.pdf;
Epstein_Investigative_Reports.pdf; Staff_Roster_8-10-19.pdf;Staff_Roster_8-9-19.pdf
Hi
,
I have an interview beginning at 930, could you please print a binder of these documents? Order should be:
1. Medical Records
2. Psych notes
3. Investigative Reports
4. Epstein photos
5. 30 minute rounds (oldest to newest)
6. Count Slips
7. Staff assignments
8. Staff roster (oldest to newest)
9. "attachment 1"
10. Research
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00032355


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=== Page 1 ===
Suicide Watch
1. Epstein #76318-054
Psych Observation
None
Thank you,
CONFIDENTIAL
SDNY_00009885
EFTA00034027


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=== Page 1 ===
Page I of I
NEW YORK POST
EPSTEIN EYES SEX-RAP RELIEF
October 9, 2007 -- LAWYERS for Jeffrey Epstein - the billionaire Manhattan
STAPLES
€
investment manager who's agreed to plead guilty to soliciting underage
prostitutes at his Palm Beach mansion in exchange for just 18 months in the
slammer - are mulling asking federal prosecutors to drop their demand that he
register as a sex offender. In a letter drafted, but not sent, to U.S. Attorney
Business-
Alexander Costa and obtained by Page Six, Epstein's lawyer, Gerald
Lefcourt, writes, "Doing so will have a profound impact [on Epstein] both
Bundle-A-Day
immediately and forever after. Not only will he be restricted to a wholly
inappropriate penal facility, but he will be required for the rest of his life to
GIVEAWAY
account for his whereabouts." Epstein, a former business partner of Daily
News owner Mort Zuckerman, pleaded guilty to a state charge in exchange
Enter daily to win an
for the feds' dropping their probe into possible federal criminal violations.
incredible prize package
Lefcourt argues that only the feds have demanded that Epstein register,
for your office,
"despite the fact that the state was of the view that Mr. Epstein's conduct did
There's a
not warrant registration." A rep for Epstein had no comment.
every business day!
& Enter now
Valued at
more than
550!
Home
NEW YORK POST is a registered trademark of NYP Holdings, Inc. NYPOST.COM, NYPOSTONLINE.COM, and
NEWYORKPOST.COM
are trademarks of NYP Holdings, Inc.
Copyright 2008 NYP Holdings, Inc. All rights reserved.
http://www.nypost.com/php/pfriendly/print.php?url=http//www.nypost.com/seven/1009200 6/3/2008
MM22-ATTYS LETTERS AND MISC-000124
EFTA00031936


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=== Page 1 ===
DRAFT - October 20, 2021
Juror ID:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
:
-v-
:
20 Cr. 330 (AJN)
:
GHISLAINE MAXWELL,
:
JURY
QUESTIONNAIRE
:
Defendant.
:
:
X
INSTRUCTION SHEET
Dear Juror:
Please call (212) 805 0158 on November 15, 2021 after 6:00 p.m. for further reporting
instructions. Please bring this instruction sheet with you to the courthouse if you are
instructed to return.
-1-
EFTA00032823

=== Page 2 ===
Juror ID:
[INSERT JUROR INFORMATION SHEET FROM JURY DEPARTMENT
-2-
EFTA00032824

=== Page 3 ===
Juror ID:
PRELIMINARY INSTRUCTIONS
Please read the following instructions carefully before completing any portion of this
questionnaire. Please print your juror number in the space provided at the top of each page.
Do not write your name on the questionnaire. Please answer each and every question fully.
Some questions have more than one part.
YOU ARE SWORN TO GIVE TRUE AND COMPLETE ANSWERS TO ALL
QUESTIONS IN THIS QUESTIONNAIRE. This questionnaire is designed to help simplify
and shorten the jury selection process. The purpose of the questionnaire is to determine
whether prospective jurors can decide this case impartially based upon the evidence presented
at trial and the legal instructions given by the presiding judge. The questions are not intended
to inquire unnecessarily into personal matters. Although some of the questions may appear to
be of a personal nature, please understand that the Court and the parties must learn enough
information about each juror's background and experiences to select a fair and impartial jury.
Please answer all questions to the best of your ability. If you do not know the answer to a
question then write, "I don't know." There are no "right" or "wrong" answers, only truthful
answers. If you have strong feelings about this case in general, please do not hesitate to share
them. Although you may be a perfectly good juror in another case, this may or may not be the
right case for you to sit on as an impartial juror. Both parties have the right to get honest
answers and to hear your true opinions. Do not discuss the case or your answers with anyone.
It is important that the answers be yours alone. Remember, you are sworn to give true and
complete answers to all questions.
If you need extra space to answer any question, please use the extra blank sheets of paper
included at the end of the questionnaire. Be sure to indicate on the blank page the number of
the question you are answering. Do not write anything on the back of any page.
DO NOT DISCUSS YOUR QUESTIONS AND ANSWERS OR THE CASE WITH
ANYONE, NOW OR UNTIL FURTHER INSTRUCTED BY THE COURT. You should
not discuss the questions or answers with fellow jurors. It is very important that your answers
be your own individual answers. More broadly, do not discuss the case with anyone, including
the lawyers (except in the presence of the Court), your fellow jurors, your family, your friends,
or anyone else. Do not communicate about the case in any way, including telephone, e-mail,
any social media app or website (such as Facebook), any communications app or website (such
as Twitter). You must also avoid reading or hearing about the case (or anyone participating in
the case) in newspapers, in magazines, on the radio or television, or on the Internet.
DO NOT DO YOUR OWN RESEARCH ON THE CASE. Do not conduct any research
into the case (or anyone participating in the case) at any time before your entire jury service
has been completed. That includes performing Internet searches, asking other people about
the case, reading news stories, books, or reports about the case, or watching films or television
programs that relate to the case. Do not read, watch, or listen to any information about this
case.
-3-
EFTA00032825

=== Page 4 ===
Juror ID:
Your name will not be disclosed or connected to this questionnaire beyond the Judge and the
parties in this case. However, if you believe that any of your answers contain private
information that could embarrass you or otherwise seriously compromise your privacy and
wish to request that the Court keep them confidential and not distribute them beyond the Judge
and parties, please indicate the particular question number at the end of the questionnaire.
SUMMARY OF THE CASE
The Court is selecting a jury for a trial commencing on Monday, November 29, 2021.
Although it is never possible to predict the length of a trial, currently this trial is expected
to last approximately six weeks.
This is a criminal case. The Defendant, Ghislaine Maxwell, has been charged in an Indictment
with various criminal offenses. The Indictment is not evidence. It simply contains the
charges-referred to as "counts"-that the Government intends to prove to the jury at trial
beyond a reasonable doubt.
The charges in the Indictment stem from allegations that from at least 1994 through 2004, the
Defendant conspired with and aided and abetted Jeffrey Epstein to entice minors to travel to
engage in criminal sexual activity, to transport minors to engage in criminal sexual activity,
and to engage in sex trafficking of a minor.
The Indictment charges the Defendant in 6 counts: Count One of the Indictment charges the
Defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage
in sexual activity for which a person can be charged with a criminal offense. Count Two
charges the Defendant with enticing a minor to travel to engage in sexual activity for which a
person can be charged with a criminal offense, and aiding and abetting the same. Count Three
charges the Defendant with conspiring with Epstein and others to transport minors to engage
in sexual activity for which a person can be charged with a criminal offense. Count Four
charges the Defendant with transporting a minor to engage in sexual activity for which a person
can be charged with a criminal offense, and aiding and abetting the same. Count Five charges
the Defendant with participating in a sex trafficking conspiracy. Count Six charges the
Defendant with sex trafficking of a minor, and aiding and abetting the same.
Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent, and before
she can be found guilty on any charge, the jury must find that the Government has proven each
element of that crime beyond a reasonable doubt.
-4-
EFTA00032826

=== Page 5 ===
Juror ID:
SCHEDULE
Potential jurors will be called back for further questioning and jury selection from
Tuesday, November 16, 2021, through Friday, November 19, 2021. Your availability
during that week will be required.
The trial will commence on Monday, November 29, 2021. The trial is expected to last
about six weeks. Generally, trial will be held five days per week, Monday through Friday,
from 9:30 a.m. until 5:00 p.m. Trial will not be held on Friday, December 24, 2021
(Christmas Eve Day) and December 31, 2021 (New Year's Eve).
If you are selected as a juror, you will be required to be present for the taking of testimony and
evidence for as long as the trial lasts. There are no plans to sequester the jury, which means
you will go home every day after court.
All jury service involves some degree of hardship. Our court and justice system depends on
citizens doing their civic duty to serve as jurors, which involves temporarily putting aside their
regular business for jury service. The Court views service on a jury to be one of the highest
duties a citizen owes to the United States. Mere inconvenience or the usual financial hardship
of jury service will not be sufficient to excuse a prospective juror. You must show
extraordinary personal or financial hardship to be excused from service.
-5-
EFTA00032827

=== Page 6 ===
Juror ID:
PLEASE ANSWER THE FOLLOWING QUESTIONS:
ABILITY TO SERVE
Please note: In the event you are excused from service on this jury, you will likely
not be excused from jury service in general. You will instead be required to report to
the Court's Jury Clerk for placement on another panel for another case.
1.
Do you have any unmovable commitments between November 16, 2021, and
November 19, 2021, which is when jury selection will take place?
Yes
No
1a.
If yes, please explain (without indicating the name of where you work or the names
of any family members or friends, or other personal information that might identify
who you are):
2.
Do you have any unmovable commitments between November 29, 2021, and
approximately January 15, 2022, which is the estimated length for trial?
Yes
No
2a.
If yes, please explain (without indicating the name of where you work or the names
of any family members or friends, or other personal information that might identify
who you are):
3.
Do any circumstances exist such that serving on the jury in this case would entail
serious hardship or extreme inconvenience?
Yes
No
3a.
If yes, please briefly describe the serious hardship or extreme inconvenience:
-6-
EFTA00032828

=== Page 7 ===
Juror ID:
4.
Do you have any personal commitments that would make it difficult for you to get
to court by 9:30 a.m., every day of trial, or remain at the courthouse until 5:00 p.m.?
(Please note, the Court will arrange and provide transportation to and from the
Courthouse each day for selected jurors).
Yes
No
4a.
If yes, please explain why you would be unable to get to court by 9:30 a.m. or
remain until 5:00 p.m.:
5.
Do you have any difficulty reading, speaking, or understanding English?
Yes
No
6.
Do you have any medical, physical, or mental condition or illness that makes you
unable to serve on a jury, including difficulty hearing, seeing, reading, or
concentrating?
Yes
No
6a.
If yes, please briefly describe the condition or illness. If you believe you could serve
as a juror if such condition were accommodated in some way, please state the
accommodation.
7.
Are you taking any medication which would prevent you from giving full attention
to all the evidence at this trial?
Yes
No
7a.
If yes, please explain:
-7-
EFTA00032829

=== Page 8 ===
Juror ID:
8.
Do you have any religious, philosophical, or other beliefs that would make you
unable to render a verdict in a criminal case?
Yes
No
8a.
If yes, please explain:
BASIC LEGAL PRINCIPLES AND MEDIA RESTRICTIONS
9.
Under the law, the facts are for the jury to determine and the law is for the Judge to
determine. You are required to accept the law as the Judge explains it to you even if
you do not like the law or disagree with it, and you must determine the facts
according to those instructions. Do you accept this principle, and will you be able to
follow the Judge's instructions if selected to serve on this jury?
Yes
No
9a.
If no, please explain:
10.
The law provides that a defendant in a criminal case is presumed innocent at all
stages of the trial and is not required to put on any defense at all. The Government
is required to prove the defendant guilty beyond a reasonable doubt on each charge.
Do you accept these principles, and will you be able to apply them if selected to
serve on this jury?
Yes
No
10a.
If no, please explain:
-8-
EFTA00032830

=== Page 9 ===
Juror ID:
11.
The law provides that a defendant in a criminal case has an absolute right not to
testify, and that a juror cannot hold it against the defendant if she chooses not to
testify. Do you accept this principle, and will you be able to apply it if selected to
serve on this jury?
Yes
No
1 1a.
If no, please explain:
12.
A juror is required by law to make his or her decision based solely on the evidence
or lack of evidence presented in Court, and not on the basis of conjecture, suspicion,
bias, sympathy, or prejudice. Do you accept this principle, and will you be able to
apply it if selected to serve on this jury?
Yes
No
12a.
If no, please explain:
13.
Under the law, the question of punishment is for the Court alone to decide, and thus
the issue of punishment must not enter into your deliberations as to whether the
defendant is guilty or not guilty as charged. Do you accept this principle, and will
you be able to apply it if selected to serve on this jury?
Yes
No
13a.
If no, please explain:
-9-
EFTA00032831

=== Page 10 ===
Juror ID:
14.
You may hear testimony in this case that law enforcement officers recovered certain
evidence from searches. The Court will instruct you that those searches were legal
and that the evidence obtained from those searches is admissible in this case. Do
you have any feelings or opinions about searches conducted by law enforcement
officers, or the use of evidence obtained from searches, that would affect your
ability to be fair and impartial in this case?
Yes
No
14a.
If yes, please explain:
15.
You also may hear testimony in this case from expert witnesses. Have you had any
experiences with experts, or do you have any general feelings about the use of
experts, that would affect your ability to be fair and impartial in this case?
Yes
No
15a.
If yes, please explain:
16.
As instructed above, from now and until your jury service is complete, you are
instructed to avoid all media coverage and not to go on the Internet with regard to
this case for any purpose. That is, you are forbidden from consuming any news
media or social media, or any discussion of this case (or of anyone participating in
the case) outside of the courtroom whatsoever. You also must not discuss this case
with anyone. This includes your family, friends, spouse, domestic partner,
colleagues, and co-workers. These instructions apply from now and until you are
either dismissed from jury selection or chosen as a juror and the trial is complete.
When we return for the next step in jury selection, the Judge will ask you if you
have followed this instruction.
Do you have any reservations or concerns about your ability or willingness to
follow this instruction?
Yes
No
-10-
EFTA00032832

=== Page 11 ===
Juror ID:
16a.
If yes, please explain:
PRIOR JURY SERVICE
17.
Have you ever served as a juror in a trial in any court?
Yes
No
18.
Have you ever at any time served as a member of a grand jury, whether in federal,
state, county, or city court?
Yes
No
EXPERIENCE AS A WITNESS, DEFENDANT, OR CRIME VICTIM
19.
Have you, or has any relative or close friend, ever participated in a state or federal
court case, whether criminal or civil, as a witness, plaintiff, or defendant?
Yes (self)
Yes (friend or family member)
No
19a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
19b.
If yes to 19a, please explain:
20.
Have you or any relative or close friend ever been involved or appeared as a witness
in any investigation by a federal or state grand jury or by a congressional or state
legislative committee, licensing authority, or governmental agency, or been
questioned in any matter by any federal, state, or local law enforcement agency?
Yes (self)
Yes (friend or family member)
No
-11-
EFTA00032833

=== Page 12 ===
Juror ID:
20a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
20b.
If yes to 20a, please explain:
21.
Have you, or has any relative or close friend, ever been subpoenaed for any inquiry
or investigation?
Yes (self)
Yes (friend or family member)
No
21a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
21b.
If yes to 21a, please explain:
22.
Have you, or has any relative or close friend, ever been arrested or charged with a
crime?
Yes (self)
Yes (friend or family member)
No
22a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
22b.
If yes to 22a, please explain:
-12-
EFTA00032834

=== Page 13 ===
Juror ID:
23.
Have you, or has any relative or close friend, ever been the subject of any
investigation or accusation by any grand jury, state or federal, or any other
investigation?
Yes (self)
Yes (friend or family member)
No
23a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
23b.
If yes to 23a, please explain:
24.
Have you, or any of your relatives or close friends, ever been a victim of a crime?
Yes (self)
Yes (friend or family member)
No
24a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
24b.
If yes to 24a, please explain:
25.
Have you, or has any member of your family or any of your close friends-either as
individuals or in the course of their business affairs-ever been a party to a legal
action or dispute with the United States, or with any of the officers, departments,
agencies, or employees of the United States, including the United States Attorney's
Office, the FBI, or the NYPD?
Yes (self)
Yes (friend or family member)
No
-13-
EFTA00032835

=== Page 14 ===
Juror ID:
25a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
25b.
If yes to 25a, please explain:
26.
Have you, or has any member of your family, ever had a dispute concerning money
owed to you by the Government or owed by you to the Government?
Yes (self)
Yes (friend or family member)
No
26a.
If yes, is there anything about that experience that would prevent you from acting as
a fair and impartial juror in this case?
Yes
No
26b.
If yes to 26a, please explain:
RELATIONSHIP WITH, AND VIEW OF, GOVERNMENT, DEFENSE, AND
OTHERS
27.
Do you or any member of your family or a close friend work in law, law
enforcement, the justice system, or the courts?
Yes
No
27a.
If yes, please explain:
-14-
EFTA00032836

=== Page 15 ===
Juror ID:
27b.
If yes to 27, would this affect your ability to serve as a fair and impartial juror in
this case?
Yes
No
27c.
If yes to 27b, please explain:
28.
Do you know or have any association-professional, business, or social, direct or
indirect-with any member of the staff of the United States Attorney's Office for
the Southern District of New York?
Yes
No
28a.
If yes, please explain:
28b.
If yes to 28, would this affect your ability to serve as a fair and impartial juror in
this case?
Yes
No
28c.
If yes to 28b, please explain:
29.
Do you know or have any association-professional, business, or social, direct or
indirect-with the Federal Bureau of Investigation, commonly known as the FBI?
Yes
No
29a.
If yes, please explain:
-15-
EFTA00032837

=== Page 16 ===
Juror ID:
29b.
If yes to 29, would this affect your ability to serve as a fair and impartial juror in
this case?
Yes
No
29c.
If yes to 29b, please explain:
30.
Do you know or have any association-professional, business, or social, direct or
indirect-with the New York City Police Department, commonly known as the
NYPD?
Yes
No
30a.
If yes, please explain:
30b.
If yes to 30, would this affect your ability to serve as a fair and impartial juror in
this case?
Yes
No
30c.
If yes to 30b, please explain:
31.
Do you have any opinion of the U.S. Attorney's Office for the Southern District of
New York or the U.S. Attorney Damian Williams that might make it difficult for
you to be a fair and impartial juror in this case?
Yes
No
-16-
EFTA00032838

=== Page 17 ===
Juror ID:
31a.
If yes, please explain:
PERSONAL RELATIONSHIP WITH CASE PARTICIPANTS
32.
The next subset of questions asks whether you or any member of your family or a
close friend personally knows or has past or present dealings with individuals
involved in this case. To "personally know" means to have some direct or personal
knowledge or connection to the following individuals. If you have only heard the
names through media or social media, for example, that is not personal knowledge.
32a.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with the Defendant in this case, Ghislaine Maxwell, or
her family members?
Yes
No
32b.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with Jeffrey Epstein?
Yes
No
32c.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with the U.S. Attorney for the Southern District of
New York, Damian Williams, or anyone else who works for or used to work for the
U.S. Attorney's Office for the Southern District of New York?
Yes
No
32d.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with any of the Assistant United States Attorneys who
are prosecuting this case:
Yes
No
Yes
No
Yes
No
Yes
No
-17-
EFTA00032839

=== Page 18 ===
Juror ID:
32e.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with any of the defense attorneys or law firms who are
representing the Defendant:
Christian Everdell of Cohen & Gresser LLP
Yes
No
Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C.
Yes
No
Laura Menninger of Haddon, Morgan and Foreman, P.C.
Yes
No
Bobbi Sternheim of Law Offices of Bobbi C. Sternheim
Yes
No
32f.
Do you or does any member of your family or a close friend personally know or
have past or present dealings with the United States District Court Judge who is
presiding over this case, Alison J. Nathan, or anyone who works on her staff?
Yes
No
32g.
If you answered "yes" to any of the above sub-questions (32a, 32b, 32c, 32d, 32e,
or 32f), please explain whom you know, how you know the individual(s), and
whether your relationship with that person might make it difficult for you to be a
fair and impartial juror in this case:
-18-
EFTA00032840

=== Page 19 ===
Juror ID:
KNOWLEDGE OF CASE AND PEOPLE
This case has been widely reported in the national and local media. There is
nothing wrong with having heard something about this case. It is important to
answer all of the following questions truthfully and fully.
33.
Before today, had you read, seen, or heard anything about Ms. Maxwell?
Yes
No
Unsure
33a.
If yes or unsure, please state what you remember hearing, and how or from whom
you may have heard (e.g., a friend, the newspaper, a website, social media). If you
heard about Ms. Maxwell from a media source, please identify the media source by
name:
34.
Have you personally formed an opinion about Ms. Maxwell's guilt or innocence of
the crimes charged as a result of anything you have heard, read or seen?
Yes
No
Unsure
Not applicable, I have not read/seen/heard about Ms. Maxwell
34a.
If yes or unsure, please summarize your opinion:
-19-
EFTA00032841

=== Page 20 ===
Juror ID:
35.
Based on anything that you have read, seen, or heard about Ms. Maxwell, including
anything about criminal charges against Ms. Maxwell, have you formed any
opinions about Ms. Maxwell that might make it difficult for you to be a fair and
impartial juror in this case?
Yes
No
Unsure
Not applicable, I have not read/seen/heard about Ms. Maxwell
35a.
If yes or unsure, please explain why it might be difficult for you to be a fair and
impartial juror in this case:
36.
Before today, had you read, seen, or heard anything about Jeffrey Epstein?
Yes
No
Unsure
36a.
If yes or unsure, please state what you remember hearing, and how or from whom
you may have heard (e.g., a friend, the newspaper, a website, social media). If you
heard about Mr. Epstein from a media source, please identify the media source by
name:
37.
Have you verbally stated or posted your opinion on social media or online about
Ms. Maxwell or Mr. Epstein?
Yes
No
Not applicable, I have not read/seen/heard about Mr. Epstein/Ms. Maxwell
37a.
If yes, when and where did you state or post your opinion?
-20-
EFTA00032842

=== Page 21 ===
Juror ID:
38.
Based on anything that you have read, seen, or heard about Jeffrey Epstein, have
you formed any opinions about Mr. Epstein that might make it difficult for you to
be a fair and impartial juror in this case?
Yes
No
Unsure
Not applicable, I have not read/seen/heard about Mr. Epstein
38a.
If yes or unsure, please explain why it might be difficult for you to be a fair and
impartial juror in this case:
39.
If you have heard about Jeffrey Epstein, do you think Ms. Maxwell's alleged
association with Jeffrey Epstein will make it difficult for you to fairly and
impartially consider the evidence presented at trial and render a verdict based solely
on the evidence?
Yes
No
Unsure
Not applicable, I have not read/seen/heard about Ms. Maxwell and/or
Jeffrey Epstein
39a.
If yes or unsure, please explain:
40.
Based on anything you have read, seen, or heard about Ms. Maxwell, including
anything about criminal charges brought against Ms. Maxwell, would you be able to
follow the Court's instruction to put that information out of your mind and decide
this case based only on the evidence presented at trial?
Yes
No
Unsure
Not applicable, I have not read/seen/heard about Ms. Maxwell
-21-
EFTA00032843

=== Page 22 ===
Juror ID:
40a.
If no or unsure, please explain:
NATURE OF CHARGES
41.
During the trial, you will hear evidence alleging sex crimes against underage girls.
Some of the evidence in this case will involve sexually suggestive or sexually
explicit conduct. Is there anything about the nature of this case and the accusations
as summarized at the beginning of this questionnaire that might make it difficult for
you to be a fair and impartial juror in this case?
Yes
No
41a.
If yes, please explain:
42.
Do you have any specific views or feelings concerning laws regarding the age at
which individuals can or cannot consent to sexual activity with other individuals
that would affect your ability to serve as a fair and impartial juror?
Yes
No
42a.
If yes, please explain:
43.
Do you have any opinion about the enforcement of the federal sex trafficking laws
or the federal laws concerning sex crimes against minors that might prevent you
from being fair and impartial in this case?
Yes
No
-22-
EFTA00032844

=== Page 23 ===
Juror ID:
43a.
If yes, please explain:
44.
Have you or a family member ever lobbied, petitioned, or worked in any other
manner for or against any laws or regulations relating to sex trafficking, sex crimes
against minors, or sex abuse generally?
Yes
No
44a.
If yes, please explain when and what you or your family member did:
44b.
If your answer to 44 was yes, do you believe that this would affect your ability to
serve fairly and impartially as a juror in this case?
Yes
No
44c.
If yes to 44b, please explain:
45.
The witnesses in this case may include law enforcement witnesses. Would you have
any difficulty assessing the credibility of a law enforcement officer just like you
would any other witness?
Yes
No
45a.
If yes, please explain:
-23-
EFTA00032845

=== Page 24 ===
Juror ID:
46.
Witnesses in this case may testify claiming sexual abuse or sexual assault. Would
you have any difficulty assessing the credibility of a witness claiming sexual assault
or abuse just like you would any other witness?
Yes
No
46a.
If yes, please explain:
47.
Have you or a friend or family member ever been the victim of sexual harassment,
sexual abuse, or sexual assault? (This includes actual or attempted sexual assault or
other unwanted sexual advance, including by a stranger, acquaintance, supervisor,
teacher, or family member.)
Yes (self)
Yes (friend or family member)
No
47a.
If yes, without listing names, please explain:
47b.
If your answer to 47 was yes, do you believe that this would affect your ability to
serve fairly and impartially as a juror in this case?
Yes
No
47c.
If yes to 47b, please explain:
-24-
EFTA00032846

=== Page 25 ===
Juror ID:
48.
Have you or a friend or family member ever been accused of sexual harassment,
sexual abuse, or sexual assault? (This includes both formal accusations in a court of
law or informal accusations in a social or work setting of actual or attempted sexual
assault or other unwanted sexual advance, including by a stranger, acquaintance,
supervisor, teacher, or family member.).
Yes (self)
Yes (friend or family member)
No
48a.
If yes, without listing names, please explain:
48b.
If your answer to 48 was yes, do you believe that this would affect your ability to
serve fairly and impartially as a juror in this case?
Yes
No
48c.
If yes to 48b, please explain:
49.
Is there any other experience that you or anyone close to you has had that may
affect your ability to serve fairly and impartially as a juror in this case?
Yes
No
49a.
If yes, please explain:
-25-
EFTA00032847

=== Page 26 ===
Juror ID:
CLOSING QUESTION
50.
Do you wish for any particular answers to remain confidential and to not go beyond
the Judge, counsel, and the Defendant, because the answer would embarrass you or
otherwise seriously compromise your privacy?
Yes
No
If yes, please list which question number(s):
-26-
EFTA00032848

=== Page 27 ===
Juror ID:
DECLARATION
I, Juror Number
declare under penalty of perjury that the foregoing answers set forth in
this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not
discussed my answers with others, or received assistance in completing the questionnaire.
Signed this
day of November, 2021
DO NOT WRITE YOUR NAME. PLEASE SIGN USING YOUR JUROR NUMBER.
-27-
EFTA00032849

=== Page 28 ===
Juror ID:
You may use these pages to finish any answers that you could not fit in the spaces
provided above. If you write anything below, please indicate the number of the relevant
question.
-28-
EFTA00032850

=== Page 29 ===
Juror ID:
-29-
EFTA00032851

=== Page 30 ===
Juror ID:
-30-
EFTA00032852

=== Page 31 ===
Juror ID:
-31-
EFTA00032853


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=== Page 1 ===
To:
From:
Sent:
Fri 8/16/2019 8:43:36 AM
Subject: Daily Activities Report/Lieutenants Log...8-15-2019
Daily Activities Report 8-15-2019.docx
LIEUTENANT'S LOG 08-15-2019.docm
CONFIDENTIAL
SDNY_00009088
EFTA00033670


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 22:28:30 +0000
Attachments: Defense_Reply_to_Dkt_350.pdf 2021.10.15_Decision_re_Legal_Mail_.pdf
Attaching the defense's letter reply and Judge Nathan's endorsement to our letter declining to enter the requested order,
but setting forth her "firm expectation" that a defendant in a pre-trial posture like GM will "in most circumstances receive
legal mail within approximately 1 business day" and allowing the defense to renew the request "if another delay occurs."
From: BOBBI C STERNHEIM
Sent: Friday, October 15, 2021 5:55 PM
To:
is
(USANYS)
is
>;
)
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 14, 2021, at 7:46 PM, BOBBI C STERNHEIM <bcsternheim@mac.com> wrote:
EFTA00032797

=== Page 2 ===
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
EFTA00032798


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=== Page 1 ===
90A-NY-3151227 Serial 60
1 = of 1-
FD-302 (Rev. 5-8-10)
FEDERAL BUREAU OF INVESTIGATION
Date of entry 08/27/2019
On 8/26/2019, CART received one (1) Gold/Black Apple iPhone, model A1920,
S/N:
,
IMEI:
evidence item 1B44, for extraction.
Writer started examination for 1B44 on 08/26/2019 and performed a device
extraction pursuant to a signed consent to search form, dated 08/26/2019.
Writer submitted a Mobile Device Unlock Service Request (MDUS) to the
Electronic Device Analysis Unit (EDAU) for a Full File System extraction.
EDAU furnished MDUS Number 10754 for reference.
Investigation on 08/26/2019 at New York, New York, United States (In Person)
File # 321C-NY-A6382037-MOBILE, 90A-NY-3151227
Date drafted 08/26/2019
by
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.
SDNY_MT_00000198
EFTA00033567


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Cc:
Subject: AUSA's
&
London 10/20/20
Date: Fri, 02 Oct 2020 16:27:52 +0000
Importance: High
Attachments:
London_10.12.20.pdf;
_London_10.12.20.pdf
Hi
&
See the travel advisory below.
You should ASAP, send a brief email to the
mailbox, giving EOUSA a heads up & asking
for guidance about your request for their approval.
Include the PDF's attached here.
Mention that you will send the airfare shortly, as well as your intent to forward your travel authorizations to them via E2
shortly.
Foreign Travel Guidance During the COVID-19 Pandemic
State Department Travel Advisory
The Department of State has issued travel advisories to Level 4 (Do Not Travel) designated locations. They also advise to reconsider
travel abroad at this time due to the impact of COVID-19. Many areas throughout the world are experiencing outbreaks and are taking
actions that may limit traveler mobility, including quarantines and border restrictions. Even countries without reported cases of COVID-
19 are taking measures and may restrict travel without notice. Please view the Department of State's Travel Advisory Webpage for the
most updated information.
Official Passports
Due to public health measures to limit the spread of COVID-19, effective immediately, the Department of State's Special Issuance
Agency (SIA) are only offering service to issue passports for customers with a qualified life-or-death emergency with a need to be issued
a passport for international travel within 72 hours. SIA defines life-or-death as a serious illness, injury, or death in one's immediate family
(e.g., parent, sibling, aunt, uncle, dependent, etc.). This means official passports will not be processed during this time until further
notice. If an employee without an official passport needs to complete essential international travel, and they have a valid tourist
passport, they must obtain approval from the host country via email to travel in their official capacity on a tourist
passport, and submit that approval with all of the usually required foreign travel documentation and approvals to
Fly America Act
Please email the
mailbox if you have a safety related need to request an exception to the Fly America Act
If you have any additional questions or concerns regarding this matter, please contact the RMP Travel Staff at
Original Message
From:
Sent: Thursday, October 1, 2020 3:03 PM
To:
Cc:
Subject: Travel
Hi
EFTA00032480

=== Page 2 ===
Should we go ahead and book our travel at this point? If so, should we go through
or is there someone
else we should contact? We have our dates set, so we can submit our paperwork now, but let us know if we should book
travel first.
Thanks so much,
Sent from my iPhone
EFTA00032481


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=== Page 1 ===
To:
From:
Sent:
Sun 8/11/2019 1:59:16 AM
Subject:
Epstein, Jeffrey Edward, Reg. No. 73618-054 re: Atty Conf Log book (Pt 1-4)
TEXT.htm
Epstein Atty Conf Pt 1.pdf
Epstein Atty Conf Pt 2.pdf
Epstein Atty Conf Pt 3.pdf
Epstein Atty Conf Pt 4.pdf
see attachment:
MCC New York
150 Park Row
New York, NY 10007
gov
CONFIDENTIAL
SDNY_00009294
EFTA00033785


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=== Page 1 ===
To:
From:
Sent:
Tue 7/30/2019 11:42:09 AM
Subject:
Suicide Watch/Psych Observation Update
TEXT.htm
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Thank you,
CONFIDENTIAL
SDNY_00009892
EFTA00034029


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=== Page 1 ===
From:
"
=
To:
)"
Subject: Accepted: Meet re Epstein forfeiture
Date: Wed, 04 Dec 2019 19:18:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00032858


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=== Page 1 ===
Documentation re: Epstein, Jeffrey Edward, Reg. No. 73618-054
(deceased)
SENTRY
PP44
PP37 (ARS, QTR)
PP41
PP78
PPGO
PD15 (Pending, Chrono)
PP85
PR15
BOPWare label
Administrative Detention (AD) Order 7/29/19
Inmate Personal Property Record (BP-A0383)
Electronic Medical Record (BEMR)
Psychology Data System (PDS)
Psychology Observation Log books 7/8-10/19 and 7/24-30/19
Suicide Watch Chronological log 7/23 & 24/19 and
Documentation re: Reyes, Efrain, Reg. No. 85993-054 (cellmate)
Court documentation regarding WAB 8/9/19
SHU file
Staff memos
Dr.
Acting Chief Psychologist
IDO
CO
Miscellaneous
Press Release
Relevant emails
Lt's log Friday, 8/9/19
CONFIDENTIAL
SDNY_00009285
EFTA00033782

=== Page 2 ===
SHU report - weekly review dated 8/8/19
SHU roster 8/8 & 9/19
SRO review roster 8/6/19
TRUSCOPE visual search log for Epstein
TRUSCOPE all log for Epstein
TRUSCOPE all log for Reyes
Visual search log book
Attorney Conference log book
CONFIDENTIAL
SDNY_00009286
EFTA00033783


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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Thursday, July 25, 2019
Beginning Count: 774
SHU: 71/5
Daily Sensitive Information:
M/W
I/M Epstein #76318-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
774
71/5
Operations Lieutenant. The fire alarm and sprinkler system are
nonoperational. Fire Watch in progress. PREA announcement
conducted via the Institution Public Address System and/or Radio.
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate/Facilities/R&D. Roof Check
completed. All secure. Temporary Chit Inventory: #1:2; #2:5; #3:5;
#4:6; #5:5; #6:0; Hosp:0
12:00 AM
Institution Count in progress
12:00 AM
NYPD Phone Check #1463
12:15 AM
Body Alarm testing in progress
12:26 AM
Body Alarm testing completed
12:30 AM
Watch Calls/Fire Watch cont.
12:33 AM
Good Verbal count announced
12:37 AM
Clear Institution count announced
774
71/5
3:00 AM
Institution Count in progress
3:33 AM
Good Verbal count announced
3:35 AM
Clear Institution count announced
774
71/5
4:45 AM
Town Driver exits inst.
5:00 AM
Institution Count in progress
5:36 AM
Good Verbal count announced
5:43 AM
Clear Institution count announced
774
71/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
774
71/5
STG International Terrorist phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 774 SHU: 71; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
SHIFT-DAY-DATE: D/W - Thursday, July 25, 2019
Beginning Count: 774
SHU: 71/5
SDNY_00008230
EFTA00033444

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
D/W
Daily Sensitive Information:
I/M
#76254-054 at Gold crest nursing facility w/USMS Guards.
I/M Epstein on Psych obs. w/inmate companion
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
774
71/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate. Roof Check completed. All
secure. Temporary Chit Inventory: #1:0; #2:5; #3:5; #4:6; #5:6;
#6:5; Hosp:0
Daily Hand Stamp : GPKJ/LEFT HAND
8:00 AM
NYPD Phone Check #2389
8:23 AM
Body Alarm Test Initiated.
8:30 AM
AM Census Conducted
8:48 AM
Body Alarm Testing Complete.
9:00 AM
Lock Down Census Count Begin
10:10 AM
Lock Down Census Count Complete
11:00 AM
Mainline Conducted
12:30 PM
PM Census Conducted
12:30 PM
I/M
#53634-424 out to Court
773
71/5
12:30 PM
I/M
#79662-054 out to L-Hosp
772
70/5
2:00 PM
I/M
#79662-054 return from L-Hosp.
773
71/5
1:05 PM
-2 I/M
#74458-053,
#86974-054
771
71/5
1:30 PM
I/M
#86931-054 Placed in SHU
771
72/5
3:23 PM
-1 Bail Bond; I/M
#89579-053
770
72/5
3:34 PM
+1 court return; I/M
#53634-424
771
72/5
3:45 PM
Institutional lockdown for count.
771
72/5
4:00 PM
Relieved of duties by Lt.
as E/W Operations Lieutenant.
Visitation: 9 North
Inmates
Adults
Children
Total
23
32
7
62
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
86931-054
Possession of Cell Phone
KN
1:30 PM
YES
Ops Lt
Ending Count: 771 ; SHU: 72; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
SDNY_00008231
EFTA00033445

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: E/W Thursday, July 25, 2019
Beginning Count: 771
SHU: 72/5
Daily Sensitive Information.
E/W
I/M
#76254-054 at Goldcrest nursing facility w/USMS Guards
I/M Epstein #76318-054 on Suicide Watch. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch Operations
Lieutenant. The fire alarm and sprinkler system are inoperable Fire
Watch is in progress. Unable to conduct PREA announcement over the
4:00 PM
Institution Public Address System, due to, system malfunction.
771
72/5
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:03 PM
NYPD Phone Check #1506
4:02 PM
Body Alarm testing in progress.
4:40 PM
Body alarm testing completed.
4:44 PM
Good verbal announced.
4:51 PM
Clear institutional count.
771
72/5
5:35 PM
-1 bail bond; I/M
#06600-052
770
72/5
6:00 PM
Watch call in progress
6:25 PM
3 I/M to special housing;
#08820-070,
#79465-054,
770
75/5
and
#86132-054
8:30 PM
Trash run in progress
9:25 PM
Trash run complete
10:00 PM
Institutional count in progress.
10:55 PM
Good verbal count announced.
10:56 PM
Clear institutional count announced.
770
75/5
12:00 AM
Relieved of duties by
M/W Lieutenant.
770
75/5
VISITING: 5 NORTH
INMATES
ADULTS
CHILDREN
TOTAL
27
28
18
73
STG/High Alert phone calls monitored: 10
WITSEC inquiry(s was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
08820-070
108
GN
6:25 PM
Yes
79465-054
108
GN
6:25 PM
Yes
86132-054
108
GN
6:25 PM
Yes
Ops. Lt.
Ending Count: 770 ; SHU: 75; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
SDNY_00008232
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=== Page 1 ===
From:
Subject: RE: FW: Requests
Date: Tue, 30 Jun 2020 14:50:48 +0000
Thanks for the explanations.
From:
Sent: Friday, June 26, 2020 1:15 PM
To:
Subject: RE: FW: Requests
I hope this provides further clarity.
-
For the "Hot List" (or the high risk list), it is dated August 30, 2019, which is after the events in question. Do you
have these from the period of June 26, 2019 through August 10, 2019? The hot list file provided begins with
the AUG 30 list. If you scroll down, you'll find previous lists going back to the beginning of July 2019. The
list is updated and re-distributed anytime someone is added or removed from the list. The inmate of
interest here was never placed on the hot list.
-
You are still working on getting us the following:
Finalized versions of Program Statements 5511.08 and 5500.13;
An updated suicide prevention PowerPoint presentation; and
Watch call tracking sheets Yes to all of this.
-
Finally, with respect to our request for all SROs during the time of
assignment to the SHU, that seems
excessively burdensome. Rather, if possible, can you locate the SROs related to Epstein only? The head of the
records department at MCC, who is Case Management Coordinator Schnahider Demosthenes reported the
central file for Epstein was taken by the FBI following the inmate's death. I've asked him to double check
that just to make sure and I'll let you know if anything changes. If the file was taken, any SROs would have
been included in that file and are no longer accessible to us.
Is there something called a "SHU report" that is different from an SRO? Yes, I'm trying to see if MCC
maintains old copies of these. Much like the LTs logs, in previous institutions I've worked at, these
were filed for one year but I don't know the practice at MCC. I do believe there is a copy of the last
one that Epstein appeared on that I will try to track down. The SHU report is a document that
contains the name and photo of each inmate in the SHU at a given time. The report also contains
comments specific to each inmate by a number of different departments. As with the other things
I'm waiting on, I'll send what I'm able to dig up as soon as I find it.
06/26/20 11:00 AM
Thank you very much for this extremely clear and helpful email. Just a few follow-up points:
For the "Hot List" (or the high risk list), it is dated August 30, 2019, which is after the events in question. Do you
have these from the period of June 26, 2019 through August 10, 2019?
-
You are still working on getting us the following:
Finalized versions of Program Statements 5511.08 and 5500.13;
An updated suicide prevention PowerPoint presentation; and
Watch call tracking sheets
EFTA00032572

=== Page 2 ===
Finally, with respect to our request for all SROs during the time of
assignment to the SHU, that seems
excessively burdensome. Rather, if possible, can you locate the SROs related to Epstein only?
Is there something called a "SHU report" that is different from an SRO?
From:
Sent: Thursday, June 25, 2020 6:21 PM
To:
Subject: Re: FW: Requests
All,
I hope my responses below serve to clear up some of the issues you had with the documentation that was provided. I
continue to work to obtain the missing items and will send them as I receive any additional documents. Please let me
know if you have further questions and I'll be happy to address anything that is still unclear.
Many of the requests made, such as ICT agenda, cellmate policies and SHU policies are not one-stop-shops.
These issues are covered in a number of different policies, therefore I tried to include all policies that
reference those topics.
1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
Executive Assistant Lee Plourde handles the finalizing of the supplements. He's on leave and will
address this upon his return on Monday, June 29, 2020.
2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive
to? Section 310 of this policy covers inmate accountability in the SHU. You requested 5511.08 and
this section in the CSPM overlaps some of those same policies.
3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
This policy covers staff training requirements for ICT and Quarterly SHU training. I included the
policy because it directly correlated with other requests.
4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive
to? When is this document from? The slide show is the Psychology portion of the SHU Training you
requested. It is dated 1/2/2014. I have requested an updated version that would have been used
more closely to the time of
assignment to SHU. I'm just waiting for Psychology staff to
provide me whatever it is they used at that time.
5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our
requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request
one from a time when the defendants were actively employed at MCC (so before August 2019). This is the
Institutional Familiarization (IF) outline you requested. It hasn't been called IF for a few years. It
is now Introduction to Correctional Techniques (ICT). An earlier version is attached here.
6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this
responsive to? When is this document from? The slide show was created 1/2/2014 as a part of
quarterly SHU training. The quarterly SHU training is primarily conducted through the BOP's online
training platform that is a self-guided course that covers a number of topics related to SHU. The
official SHU training course is not something I can send or save due to the nature of the course
being automated by the training platform and not a hard file.
7. The BOP Code of Ethics is highlighted below. Which document is this? Program Statement 3420.11 is the
Standards of Employee Conduct, which covers the dos and don'ts of employment in the BOP. I've
attached the DOJ Ethics Handbook here. If there is something specific you're looking for, please let
me know.
8. We received digital lieutenant's logs. Is there also a hard copy book? There is no hard copy book of these
logs. The logs are saved to a shared folder at the end of each shift. Although I have worked at
places that print each log, the Lieutenant's here at NYM reported that that is not the practice here.
The LTs here email their logs to the executive staff at the conclusion of each 24 hour period for
review purposes. Thus, eliminating a hard copy record system.
9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm
what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs. Those are the
digital log books from SHU for the Evening and Morning Watch shifts during the requested time
period. I am working on obtaining the actual Watch Call tracking sheets from the main Control
Center at MCC which is something different. However, the officer should be logging their watch
calls into the digital log book every 30 minutes between 6a - 6p each day.
EFTA00032573

=== Page 3 ===
10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as
having been provided? PS 5270.11 as well as the Suicide Prevention policy covers the SHU quarterly
training requirement. There is not a separate policy for that.
11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request
incorrect? 5270.10 does not exist. 5270.11 is the policy covering SHU.
12. Which document contains the BOP and MCC policy on cellmates? I am not aware of any such policy and
have struggled to find even a mention of it in the policies I've reviewed. I will continue to search
for a policy that references cellmate assignments.
13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this
responsive to? The "Hot List" is the high risk list. Any inmate on that list who goes to SHU requires
immediate notification to Psychology. This is the only "high risk" list the BOP has and I provided it
in response to your request for "All High Risk Lists reviewed during weekly SHU meetings. "
14. In the second email,
mentioned that most of the control center paperwork was seized by FBI and/or OIG.
Do you or FBI have that paperwork? Has it been provided to us?
15. Finally, what is the status of the remaining requests? As I continue to work from home, I have not
personally been able to physically search for the Watch Call sheets. As I previously mentioned,
those logs were reportedly seized early on in this investigation. I continue to follow up on this.
With regard to the SROs, those reviews are only electronically available for inmates who are
currently in SHU and only for the period of their most recent admission to SHU. SROs, assuming
they were completed, would then be printed and filed in the inmate's central file. I am currently
trying to figure out where Epstein's file is to see if any SROs are in it. If you really want ALL SROs
for the period of
assignment to SHU, that will be an extremely lengthy process of tracking
down inmate files, many of whom have released from the BOP or been transferred to any number
of institutions across the country, and then requesting any SROs from the specified period of time
that are contained in those files be scanned to us. I'm guessing Epstein's file was taken along with
all of the other documentation shortly after his death, but I have not confirmed that yet.
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
06/25/20 12:35 PM >>>
Can you please address the questions/discrepancies noted below. Much appreciated.
From:
Sent: Thursday, June 25, 2020 12:30 PM
To:
is
Cc:
is
Subject: RE: Requests
/
Some follow up questions related to these materials:
1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive
to?
3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive
to? When is this document from?
EFTA00032574

=== Page 4 ===
5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our
requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request
one from a time when the defendants were actively employed at MCC (so before August 2019).
6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this
responsive to? When is this document from?
7. The BOP Code of Ethics is highlighted below. Which document is this?
8. We received digital lieutenant's logs. Is there also a hard copy book?
9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm
what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs.
10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as having
been provided?
11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request
incorrect?
12. Which document contains the BOP and MCC policy on cellmates?
13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this
responsive to?
14. In the second email,
mentioned that most of the control center paperwork was seized by FBI and/or OIG. Do
you or FBI have that paperwork? Has it been provided to us?
15. Finally, what is the status of the remaining requests?
Please work on this as quickly as you can. Thanks!
From:
Sent: Tuesday, June 23, 2020 3:59 PM
To:
is
Cc:
Subject: FW: Requests
fyi
From:
Sent: Tuesday, June 23, 2020 3:53 PM
To:
Cc:
Subject: Re: Requests
I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email.
Let me know if you have any questions.
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
06/12/20 1:54 PM >>>
Hi
Hope you and fam have been well, as well as MCC staff.
EFTA00032575

=== Page 5 ===
Can you please provide the following information concerning the Epstein suicide investigation:
The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement
forms for Defendant Noel.
The MCC institutional familiarization training outline.
The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations,
including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
The BOP and MCC policy on SHU quarterly training.
The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
All SHU Watch Call Logs completed during Defendant
assignment to the SHU post which began on June 26,
2019.
All SHU Control Center Logs completed during Defendant
assignment to the SHU post which began on
June 26, 2019.
All SHU Operations Lieutenant Log Books completed during Defendant
assignment to the SHU post which
began on June 26, 2019.
All High Risk Lists reviewed during weekly SHU meetings during Defendant
assignment to the SHU post
which began on June 26, 2019.
All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant
assignment to the SHU
post which began on June 26, 2019.
Many thx!
EFTA00032576


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
)"
i
,
)"
Subject: RE: AJN Order - Pretrial Motions
Date: Fri, 16 Apr 2021 16:17:05 +0000
Attachments: Exhibit_11_(Proposed_Redactions_Per_Second_Order),pdf
Exhibit_11_(Proposed_Redactions_Per_Order).pdf
From:
(USANYS)
>
Sent: Friday, April 16, 2021 12:03 PM
To:
>;
)
>;
Subject: RE: AJN Order - Pretrial Motions
From:
Sent: Friday, April 16, 2021 12:02 PM
To:
(USANYS)
is
)
is
Subject: RE: AJN Order - Pretrial Motions
From:
(USANYS)
>
Sent: Friday, April 16, 2021 11:57 AM
To:
)
is
)
V.
)
Subject: AJN Order - Pretrial Motions
EFTA00032790

=== Page 2 ===
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00032791


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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Thursday, July 18, 2019
Beginning Count: 784
SHU: 75/4
Daily Sensitive Information:
M/W
I/M
#91268-054 on Suicide Watch w/inmate companion
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
784
75/4
Operations Lieutenant. The fire alarm and sprinkler system are
operational. PREA announcement conducted via the Institution
Public Address System and/or Radio. Restraint Equipment Cage
inventory conducted. All equipment accounted for. Metal Detector
checks conducted. All operative w/the exception of Rear
Gate/Facilities/R&D. Roof Check completed. All secure. Temporary
Chit Inventory: #1:2; #2:5; #3:5; #4:6; #5:5; #6:0; Hosp:0
Note:
Control Center Sallyport Door malfunctioning. Door manually
operated.
12:00 AM
Institution Count in progress
12:00 AM
NYPD Phone Check #2748
12:12 AM
Body Alarm testing in progress
12:26 AM
Body alarm testing completed
12:30 AM
Watch Calls cont.
12:48 AM
Good Verbal count announced
12:52 AM
Clear Institution count announced
784
75/4
3:00 AM
Institution Count in progress
3:25 AM
Good Verbal count announced
3:27 AM
Clear Institution count announced
784
75/4
5:00 AM
Institution Count in progress
5:43 AM
Good Verbal count announced
5:43 AM
Clear Institution count announced
784
75/4
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
784
75/4
STG International Terrorist phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 784 SHU: 75; 10-South: 04; SHU OBS: 00;
Ops Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
SDNY_00008209
EFTA00033438

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W Thursday, July 18, 2019
Beginning Count: 784
SHU: 75/4
D/W
Daily Sensitive Information:
I/M
#79792-007 on Psych Obs. w/inmate companion.
I/M
#78346-054 on Suicide Watch w/inmate companion
I/M
#91268-054 on Suicide Watch w/inmate companion
I/M
#76254-054 at Gold crest nursing facility w/USMS Guards.
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
784
75/4
Lieutenant. The fire alarm and sprinkler system are operational.
Unable to conduct PREA announcement over the Institution Public
Address System, due to, system malfunction. Restraint Equipment
Cage inventory conducted. All equipment accounted for. Metal
Detector checks conducted. All operative w/the exception of Rear
Gate. Roof Check completed. All secure. Temporary Chit Inventory:
#1:0; #2:5; #3:5; #4:6; #5:6; #6:5; Hosp:0
Daily Hand Stamp :GPKJ/RIGHT HAND
8:00 AM
NYPD Phone Check #2352
8:23 AM
Body Alarm Test Initiated
8:30 AM
AM Census Count
8:50 AM
Body Alarm Testing Complete
9:43 AM
-1 Out to court:
#75954-054
783
75/4
9:56 AM
-1 HLD REMOVE:
#70119-054
782
74/4
10:30 AM
Mass Unit shakedown conducted on 11 south.
10:52 AM
-1 L-HOSP :
#85956-054
781
74/5
11:00 AM
Mainline feeding in progress
12:30 AM
PM Census count
781
74/4
1:30 PM
+1 L-HOSP return:
#85956-054
782
74/4
1:45 PM
Inmate
#53267-054 placed on Dry Cell watch (ZA)
782
75/4
2:23 PM
-1 L-Hosp;
#17437-104
781
75/4
3:45 PM
Institutional lockdown for count
781
75/4
4:00 PM
Relieved of duties by Lt.
as E/W Operations Lieutenant.
Visitation: 5-North
Inmates
Adults
Children
Total
17
21
5
43
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored: 0
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Ops Lt
Ending Count: 781 ; SHU: 75; 10-South: 04; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 01
SDNY_00008210
EFTA00033439

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: E/W Thursday, July 18, 2019
Beginning Count: 781
SHU: 75/4
Daily Sensitive Information.
E/W
I/M
#91268-054 on Suicide Watch w/inmate companion
I/M
#76254-054 at Goldcrest nursing facility w/USMS Guards.
I/M
#53267-054 on dry cell w/staff observation
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch Operations
Lieutenant. The fire alarm and sprinkler system are operational.
Unable to conduct PREA announcement over the Institution Public
4:00 PM
Address System, due to, system malfunction. Restraint Equipment
781
75/4
Cage inventory conducted. All equipment accounted for. Metal
Detector checks conducted. All operative w/the exception of Rear
Gate. Roof Check completed. All secure. Temporary Chit Inventory:
#1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:00 PM
NYPD Phone Check #1356.
4:35 PM
Body Alarm testing in progress.
4:55 PM
Body alarm testing completed.
5:13 PM
Good verbal announced
5:20 PM
Clear institutional count.
5:28 PM
+1 L-Hosp return;
#17437-104
782
75/4
5:29 PM
+1 Court Return;
#75954-054
783
75/4
5:50 PM
+4 new commits;
#30772-069,
#87034-054,
787
75/4
#62670-054, and
#23789-057
6:00 PM
Watch call in progress
6:50 PM
I/M
#53267-054 produced 1 clean bowel movement
7:00 PM
7 inmates from SHU to general population
787
68/4
8:00 PM
Trash run commenced.
9:15 PM
Trash run complete.
10:00 PM
Institutional count in progress.
10:41 PM
Good verbal count announced.
10:45 PM
Clear institutional count announced.
787
68/4
12:00 AM
Relieved of duties by
as M/W Operations Lieutenant.
787
68/4
VISITING: 9N
INMATES
ADULTS
CHILDREN
TOTAL
21
29
8
58
STG/High Alert phone calls monitored: 0
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
Ops. Lt.
Ending Count: 786 ; SHU: 78; 10-South: 04; SHU OBS: 00;
Act. Lt.
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
SDNY_00008211
EFTA00033440


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=== Page 1 ===
From: Dealbreaker Daily <newsletters@dealbreaker.com>
To:
Subject: Welcome To The Nonsense Economy
Date: Mon, 08 Jul 2019 22:02:51 +0000
Not rendering correctly? View this email as a web 0000
Dealbreaker
DAILY
MONDAY, JULY 8, 2019
http://dealbreaker.com/.image/c_limit%2Ccs_srgb%2Ch_1200%2Cq_auto:god%2Cw_1200MTY0NDEwNi4MDc1OTxNM3/screen-shot-2019-05-29-at-
43812-pm.png
Welcome To The Nonsense Economy
BY HIPSTER TRADER / July 8, 2019 5:43 PM
No. you're feeling is correct, none of this makes sense.
Continue reading
http://dealbreaker.com/.image/c_limit%2Ccs_srgb%2Cfl_progresive%2Ch_1200%2Cq_auto.good%2Cw_1200MTYxMjc3MTxNzQ2ODM5MDl5/chaieng
er-deutsche.jpg
Deutsche Bank Predictably Manages To Do The Right Thing In Totally The Wrong Way
BY JON SHAZAR / July 8, 2019 1:30 PM
The whole cutting-things-to-the-bone-and-firing-everyone-before-lunch thing totally would have worked seven years ago. Now? Maybe not so much.
Continue reading
http://dealbreaker.com/.image/c_limit%2Ccs_srgb2Ch_1200%2Cq_auto.good%2Cw_1200MTY1M2MOOOQ3NY2OTA4MU3/screen-shot2019-070-
at-125632-pm.png
Deutsche Bank Thanking "18,000 Volunteers" On Actual Sign Hanging In NYC HQ Today
BY THORNTON MCENERY / July 8. 2019 1:00 PM
You would think that someone in HR would be a little more sensitive to that number right now, but also this is Deutsche Bank.
Continue reading
htp://ealbreaker.com/.image/c_limit%2Ccs_srgb%2Ch_1200%2Cq_auto:god%2Cv_1200/MTY1MzMOMTAzMDIzOTUzNDgx/screen-shot201907-08-
at-121130-pm.png
Feds Allege That Ersatz Financier Jeffrey Epstein Is Indeed A Genuine Sex Criminal
BY THORNTON MCENERY / July 8, 2019 12:15 PM
Why does everyone on the Upper East Side look so nervous?
Continue reading
htp://dealbreaker.com/.image/c_limit%2Ccs_srgb%2Ch_1200%2Cq_auto:god2Cw_1200MTYMDMzODkIMDEwNTEwODQ1deutsche-ragrarokpng
Deutsche Bank Informing 18,000 People That It's Basically A Community Bank Now, And
Also They Are Fired
EFTA00032911

=== Page 2 ===
BY THORNTON MCENERY / July 8, 2019 10:51 AM
The Age of Denial is over and the Deutsche Bank we know is truly dead.
Continue reading
htp://dealbreaker.com/inage/c_imit%2Ccs_srgb%2Cf_progressive%2Ch_1200%2Cq_auto:god%2Cw_1200MTYxMic3MTxNzQ2ODM5MDI5chaieng
er-deutsche.jpg
Opening Bell 7.8.19
BY THE WATER COOLEST / July 8, 2019 6:30 AM
Deutsche Banks goes all "it's not you, it's me" to 18k employees
Continue reading
Breaking Media - 611 Broadway 907D, NY, NY 10004- Update email preferences or unsubscribe
EFTA00032912


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=== Page 1 ===
90A-NY-3151227 Serial 27
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027702
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 NYC027702: One (1) Hitachi 1TB
Hard Drive, HUA722010CLA330, S/N JPW9K0N039EZLL, containing the Clone
Copy of 1B2 hard drive (Hitachi 500GB HDD, HDS721050CLA662, S/N
JP1572JE36A13K), collected via Tableau TX-1, S/N 000ECC5801109B. Request
ID 112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027702: One (1) Hitachi 1TB Hard Drive,
HUA722010CLA330, S/N JPW9K0N039EZLL, containing the
Clone Copy of 1B2 hard drive (Hitachi 500GB HDD,
HDS721050CLA662, S/N JP1572JE36A13K), collected via
Tableau TX-1, S/N 000ECC5801109B. Request ID 112048.
Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Indiv
Located By:
Device Type: Hard Drive
Designation: Derivative
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.
EFTA00032102

=== Page 2 ===
90A-NY-3151227 Serial 27
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027702
Re: 90A-NY-3151227, 08/16/2019
Number of Devices Collected: 1
UNCLASSIFIED
2
EFTA00032103


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE:
Attorney Proffer
Date: Thu, 04 Jun 2020 21:22:41 +0000
Inline-Images: image001.jpg
Sounds good.
From:
)
Sent: Thursday, June 4, 2020 5:20 PM
To:
>;
Subject: RE:
Attorney Proffer
10:30 tomorrow works for me. Let's discuss then.
From:
Sent: Thursday, June 4, 2020 5:18 PM
To:
is
)
Subject: FW:
Attorney Proffer
Email from Bachner re:
do you guys think at this point we should try to move forward with a phone interview with
her?? I have no problem telling him we're just in a holding pattern, and we'll hold off until further notice, but I also didn't
expect on March 16 that three months later we'd be where were are.
Happy to discuss in real time, too, when we chat about the indictment. Speaking of which, what's good for people
tomorrow? I could do anytime. Say, 10:30 or 11:00? But whatever works for you both.
From: Michael Bachner
Sent: Thursday, June 04, 2020 12:27
To:
Subject: Re:
Attorney Proffer
Hey
hope all is well. Checking in to see the status of matters.
Stay well
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
EFTA00032215

=== Page 2 ===
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited.
If you have received this communication by error, please immediately notify the sender by e-mail and delete this
email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Mar 16, 2020, at 11:50 AM,
)
wrote:
Michael,
The world has obviously changed substantially even since late last week - I know we had conveyed that we wanted to
meet with Ms.
sooner rather than later, but if you and/or she has any preference at all to postpone tomorrow's
meeting, that would be fine. If she has a strong inclination to do the meeting and would *prefer* to do it tomorrow,
please let us know and we should be able to make that work at your office, but otherwise we're happy to touch base in
the coming weeks and see what makes sense. The last thing we want to do is endanger anyone's health or safety.
Please let us know what you prefer, and we'll go from there.
thanks,
From: Michael Bachner
Sent: Sunday, March 15, 2020 11:25
To:
Cc:
is
Subject: Re:
Attorney Proffer
let's do the meeting at my office on Tuesday.
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
EFTA00032216

=== Page 3 ===
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
On Mar 11, 2020, at 9:53 PM,
)
wrote:
Michael,
We'll put it in the calendar for then, certainly with the understanding that it's a fluid situation. We'll keep in touch and
hope for the best. Stay safe and we'll talk soon.
thanks,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 21:48
To:
Cc:
is
Subject: Re:
Attorney Proffer
confirming March 17 at 1030. However please I understand that these dates and times have to
remember fluid given the coronavirus situation. A resident of the The Connecticut town where
lives
just tested positive
Michael
Michael Bachner
Bachner & Weiner, PC
errors. Messages sent through dictation.
~WRD057.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
EFTA00032217

=== Page 4 ===
On Mar 11, 2020, at 5:06 PM,
)
wrote:
Michael,
We appreciate that, thank you. Shall we plan to do a first meeting on Tuesday the 17th at 10:30 a.m.? But again,
please let us know if you prefer a different time, we should be flexible that day.
thank you,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 16:32
To:
Cc:
is
Subject: RE:
Attorney Proffer
will meet earlier. How does next week look. 17 18 or 19
From:
)
Sent: Wednesday, March 11, 2020 1:04 PM
To: Michael Bachner
Cc:
in
Subject: RE:
Attorney Proffer
Sure, and given that timing I actually think it would be helpful to schedule two meetings, so we can be on track to get
all the information we need efficiently, unless you have any objection to that. Can we put meetings on the calendar
for Tuesday the 31st and Thursday the 2nd, say at 10:30 a.m. each day? Or let us know if she or you prefer different
timing.
And I would just add that because we do think she may have useful information for the ongoing investigation, which
continues to proceed, if her personal issues resolve - or allow for a meeting - sooner than those dates three weeks
out, we would prefer to meet earlier if that becomes possible. Understand if not, but wanted to note it.
thanks,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 12:30
To:
Cc:
is
Subject: RE:
Attorney Proffer
has some persona issues to deal with. Can we sometime between March 31 and April 3?
EFTA00032218

=== Page 5 ===
From:
)
Sent: Tuesday, March 10, 2020 2:37 PM
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
Thanks for getting back to us, and we could do anytime this Monday, March 16. What time that day would be good
for you and Ms.
?
thank you,
From: Michael Bachner
Sent: Monday, March 09, 2020 16:09
To:
)
Subject: RE:
Attorney Proffer
following are dates that are bad for
Please let me know dates that work for oy and I will
confirm on my calendar.
March 12
March 18-20
March 25-30
April 7-15
From: Michael Bachne
Sent: Wednesday, March 04, 2020 17:31
To:
)
Cc:
is
Subject: Re:
Attorney Proffer
in DC on biz. Get back to u soon
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<image001.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
EFTA00032219

=== Page 6 ===
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Mar 3, 2020, at 6:15 PM,
wrote:
Michael,
Wanted to get back to you, as promised - as we indicated previously, the attorney proffers we've received from you
haven't caused us to change our view of Ms.
status, and I think you've generally addressed the initial and
follow-up questions we've had. I think from our perspective the next step would be to have a conversation with
Ms.
directly, and to cover with her the same topics that we've addressed with you. Ordinarily we would
approach a discussion like that simply by going chronologically, and asking follow-up questions as appropriate along
the way, but as I've mentioned to you previously, if it would be useful to proceed in a different format, or to focus
(or avoid) specific topics in a first meeting, I think we would generally be amenable to that. And of course as we've
also discussed, any discussion would be completely voluntary-not just the interview overall, but any specific topic
or question that she wanted to pass on, or discuss with you in the moment, etc., would be totally up to her. Please
let us know what you think? We're also happy to chat via phone if that would be helpful as well.
thanks,
From:
Sent: Saturday, February 22, 2020 21:59
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
Received, thank you. This information is helpful, and as with the prior attorney proffer, does not cause us to
change our view of Ms.
status.
We will be traveling most of this upcoming week, but I hope that we will be able to follow up with you the
following week to discuss possible next steps.
thank you,
From: Michael Bachner
Sent: Friday, February 21, 2020 10:45
To:
Subject: RE:
Attorney Proffer
pls see attached replies to your questions.
From: Michael Bachner
Sent: Tuesday, February 18, 2020 12:01
EFTA00032220

=== Page 7 ===
To:
Cc:
is
Subject: RE:
Attorney Proffer
Good morning.
was away over the weekend. I expect to have a reply to your questions by
tomorrow.
From:
Sent: Saturday, February 15, 2020 3:44 PM
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't
immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now.
thanks,
From: Michael Bachner
Sent: Saturday, February 15, 2020 15:41
To:
>
Cc:
is
Subject: Re:
Attorney Proffer
Hi
J
is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment
with her husband on one occasion. I will get back to you on Monday or Tuesday regarding the other
questions you've asked today as well as at the meeting. Have a nice weekend
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<image001.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient),
you are hereby notified that any dissemination, distribution, or reproduction of this communication is
strictly prohibited. If you have received this communication by error, please immediately notify the sender
by e-mail and delete this email from your system. Nothing in this email should be construed as a legal
opinion or tax advice.
On Feb 15, 2020, at 3:05 PM,
)
wrote:
EFTA00032221

=== Page 8 ===
Michael,
Following up on our meeting, one additional question / clarification we have from reviewing our notes is about
whether Ms.
ever visited certain Epstein properties other than his New York mansion and the brief visit to
the Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of
additional questions - in particular, whether she ever visited the New Mexico ranch, the Little St. James Island,
the Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach
residence the one time you referenced? It's not a problem or issue if she visited any of those other locations, we
just wanted to clarify one way or the other. And happy to discuss via phone if that's useful.
thank you,
From:
)
Sent: Thursday, February 13, 2020 13:40
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
We do understand that your attorney proffer today will be preliminary, and to the best of your client's current
recollection and to the best of your current understanding, and without, e.g., having been provided documents or
other materials by the Government.
We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R.
Crim. P. 11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other
counsel in this case and others who have made similar statements or submissions, which is that we don't take any
position on the effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because
it doesn't implicate any rights the Government would or would not have, but you can consider us advised that
your position is that your statements are also covered under 408. (While our Office itself can't guarantee the
protections of Rule 408 because any dispute on that issue would be beyond our purview, we are also not taking
the position that we believe it does not apply.)
thank you,
From: Michael Bachner
Sent: Thursday, February 13, 2020 10:08
To:
Subject:
Attorney Proffer
Hi Alex:
Prior to our meeting today, I am writing to confirm that statements I make to you today
are preliminary and subject to further refinement once Ms.
and I have the benefit of additional
document review and refreshed recollection if necessary based upon input we may receive from your
office. My statements to you are intended in hypothetical form only and in any event, we understand that
the provisions of FRE 408 and 410 apply.
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=== Page 9 ===
Please advise if my understanding is correct.
Thanks.
Michael Bachner
Bachner & Associates, PC
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=== Page 1 ===
Inmate
is being taken off of Psych Observation.
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Pending Bedspace for SHU
1,
Thank you,
CONFIDENTIAL
SDNY_00009928
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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
)"
Cc: Christian Everdell
>, , Laura Menninger
>, , Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Mon, 18 Oct 2021 21:50:38 +0000
Attachments: Response_to_Govt_voir_dire_opposition.pdf; / ATT00001.htm
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
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=== Page 1 ===
90A-NY-3151227 Serial 75
FD-1036 (Rev. 10-16-2009)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Import Form
Form Type: EMAIL - Email
Date: 09/05/2019
Title: (U) Evidence return concurrence
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) Evidence return concurrence
UNCLASSIFIED
SDNY_MT_00000206
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Event: Tentative: Call w/ Andy Tomback and Marc Weinstein (Epstein estate)
Start Date: 2021-04-05 19:30:00 +0000
End Date: 2021-04-05 20:00:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2021-03-31 20:01:38 +0000
Date Modified: 2021-03-31 20:01:38 +0000
Priority: 5
DTSTAMP: 2021-03-31 19:41:42 +0000
Attendee:
)
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=== Page 1 ===
From: Thomas Brown
To:
)"
Cc:
)"
)"
Subject: Computer Forensics - Budget Estimate
Date: Tue, 23 Jun 2020 20:29:21 +0000
Inline-Images: image001.png; image002.png
To follow up on our conversation late last week, here is an estimate that covers the scope of work that we discussed.
Here is what I would suggest as a statement of work:
Specific deliverables known at this time include receiving, inventorying and forensically processing approximately 57
devices (a mix of computer hard drives, mobile devices, and portable media); extracting and parsing relevant data from
those devices (parsing may involve, for example, review of backups, compressed files or other data that is not initially
categorized by forensic tools); creating Relativity load files; preparing summaries and analyses of the data; and briefing
the investigative team on the contractor's findings.
As to staffing the engagement, I would propose having two junior-level staff members conduct the review, to be
supervised and assisted as necessary by a senior staff member (a former FBI computer scientist). A managing director
would have overall responsibility for the project and would coordinate with SDNY.
As to timing: we are available to start work immediately. Estimated time to complete the engagement would be 30 days
(or less).
As to a budget, I would estimate between $85,000 to $135,000 as follows:
Position
Rate
Est. Hours (Low)
Fees
Est. Hours (High)
Est. Fees
Director
$ 603.00
50
$ 30,150.00
75
$ 45,225.00
Staff
$ 356.00
150
$ 53,400.00
250
$ 89,000.00
Total
$ 83,550.00
Total
$ 134,225.00
In addition to the foregoing hourly fees, we charge $200 per blank hard drive and $45 per blank thumb drive, to the
extent they are required; as well as a fixed fee of $500 per device image (basically an equipment and software recovery
fee for the specialized tools we use for forensics).
Thank you again for considering us for this important matter.
Please let me know if you have any questions.
Best regards,
Tom
Thomas Brown I Managing Director
Berkeley Research Group, LLC
I
New York, NY 10019
I
thinkbrg.com
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BRG
BERKELEY RESEARCH GROUP, LLC (TOGETHER WITH ITS AFFILIATES, "BRG") - NOTICE
THIS EMAIL TRANSMISSION AND ANY ATTACHMENTS HERETO CONTAIN INFORMATION FROM BRG WHICH MAY BE CONFIDENTIAL AND PRIVILEGED. THE INFORMATION
IS INTENDED FOR THE SOLE USE OF THE INDIVIDUAL OR ENTITY TO WHOM IT IS ADDRESSED. IF YOU ARE NOT THE INTENDED RECIPIENT, YOUR USE, DISSEMINATION,
FORWARDING, PRINTING OR COPYING OF THIS INFORMATION IS PROHIBITED.
TAX ADVICE DISCLOSURE
ANY TAX ADVICE CONTAINED IN THIS COMMUNICATION (INCLUDING ANY ATTACHMENTS) is NOT INTENDED OR WRITTEN TO BE USED, AND CANNOT BE USED, FOR THE
PURPOSE OF (I) AVOIDING PENALTIES UNDER THE INTERNAL REVENUE CODE OR (II) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY
TRANSACTION OR MATTER ADDRESSED HEREIN.
BRG is (I) NOT A LAW FIRM AND DOES NOT PROVIDE LEGAL ADVICE AND (II) NOT A CPA FIRM AND DOES NOT PROVIDE AUDIT, ATTEST OR PUBLIC ACCOUNTING
SERVICES.
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=== Page 1 ===
From: The Washington Post <email@washingtonpost.com>
To:
Subject: The Daily 202: It's personal for the lead sponsors of the Iran war powers resolutions
Date: Fri, 10 Jan 2020 17:21:51 +0000
If you're having trouble reading this, click here.
The Daily 202
Share:
fa
lis Listen to The Big Idea
It's personal for the lead sponsors of the Iran war
powers resolutions
Rep. Elissa Slotkin (D-Mich.) gives an interview at the Capitol.
(Susan Walsh/AP)
Rep. Elissa Slotkin (D-Mich.) gives an interview at the Capitol. (Susan Walsh/AP)
ITEM.
BYLINE
BY JAMES HOHMANN
TEXT
with Mariana Alfaro
THE BIG IDEA: Rep. Elissa Slotkin (D-Mich.) is a former CIA analyst who
served three tours in Iraq as one of the American government's foremost
experts on Iranian-backed Shiite militias before being appointed as an
assistant secretary of defense with a focus on the Middle East. But that's not
the only experience that motivated Slotkin to draft the resolution limiting President
Trump's ability to take additional military action against Iran without congressional
approval, which passed the House last night on a mostly party-line vote.
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=== Page 2 ===
The freshman congresswoman's son-in-law is an active-duty Army officer
stationed at the al-Asad air base in western Iraq, which the Iranians hit with 11
ballistic missiles this week in retaliation for the drone strike that killed Quds Force
commander Qasem Soleimani. Slotkin's husband also served 30 years in the Army,
retiring as a colonel, and her stepdaughter followed in his footsteps. She was not
long ago commissioned as an active-duty Army officer.
"For me, this is not a theoretical exercise," Slotkin explained on Thursday
evening. "If our loved ones are going to be sent to fight in any protracted war, the
president owes the American public a conversation. Congress has
long
abdicated its responsibility as laid out in the Constitution to make the hard
decisions we owe our troops."
Such deeply personal investment in the war effort blunts hyperbolic attacks
from Republican lawmakers - especially those who have never served in uniform
and don't have relatives on the battlefield - that opposing the escalation of conflict
in the Middle East or supporting Congress asserting its constitutional role is
somehow unpatriotic.
The debate now moves to the Senate, which could vote as early as next
week, where it faces a more uncertain future. At least four Republicans need to
vote for the resolution to ensure passage when it comes up, as early as next week.
Whatever the Senate passes, if anything, would then need to be approved by the
House before going to Trump, who has promised a veto that there would not be the
votes to override.
Sen. Tim Kaine (D-Va.), the lead sponsor of the accompanying resolution in that
chamber, isn't just a member of the Armed Services and Foreign Relations
committees. Kaine's oldest son, Nat, is an active-duty Marine infantry officer
who has been deployed overseas multiple times.
EFTA00032519

=== Page 3 ===
McCarthy continues to accuse Pelosi of 'defending Soleimani'
-- The Republican messaging machine has gone into overdrive this
week, with what has felt at times like a competition among party leaders to see
who could offer up the most incendiary quote questioning the motives of
Democratic lawmakers concerned about the possibility of a full-scale war against
Iran without congressional approval.
"This is a meaningless vote that only sends the wrong message that the House
Democrats would rather stand with the socialist base than stand against Iran,"
House Minority Leader Kevin McCarthy (R-Calif.) said at his weekly news
conference on Thursday.
"Whether you mean to or not, you're empowering the enemy," said Sen. Lindsey
Graham (R-S.C.), the chairman of the Senate Judiciary Committee, referring to
lawmakers who vote for the resolution.
"They are in love with terrorists," said Rep. Doug Collins (R-Ga.), the top
Republican on the House Judiciary Committee. "We see that they mourn Soleimani
more than they mourn our Gold Star families," Collins told Lou Dobbs on Fox
Business.
-- Democrats have decided not to just brush aside comments like this. "I left
literal parts of my body in Iraq, where I was fighting terrorists," said Sen. Tammy
Duckworth (D-III.), who has used a wheelchair since her Black Hawk helicopter
was shot down over Iraq in 2004. "Donald Trump spent months attacking an
ACTUAL Gold Star Family," she added on Twitter. "[Collins] should be ashamed of
himself for perpetuating this offensive lie."
Duckworth is referring to when Trump, who received a deferment for "bone spurs"
to avoid being drafted during the Vietnam War, mocked Khizr and Ghazala Khan.
Their son Humayun was killed in action as an Army captain in Iraq. The Khans
EFTA00032520

=== Page 4 ===
spoke out against Trump at the Democratic convention in 2016, expressing
concern about his proposed ban on Muslims entering the United States.
-- Collins apologized this morning. "Let me be clear: I do not believe Democrats
are in love with terrorists," he tweeted. "As someone who served in Iraq in 2008, I
witnessed firsthand the brutal death of countless soldiers who were torn to shreds
by this vicious terrorist. Soleimani was nothing less than an evil mastermind who
viciously killed and wounded thousands of Americans. These images will live with
me for the rest of my life, but that does not excuse my response on Wednesday
evening."
-- During the Thursday evening debate on the House floor, several Democrats
emphasized their credentials as they made the case for the war powers
resolution. Polls suggest that Democrats have tightened their traditional gap on
which party is more trusted to handle national security. They won control of the
House in the 2018 midterm elections thanks, in part, to a large cohort of young
military veterans in swing districts. There are 96 veterans in this Congress,
including 30 Democrats and 66 Republicans.
One of those freshmen who delivered the majority is Rep. Jason Crow (D-
Colo.). He defeated a GOP incumbent in the Denver suburbs by touting his Army
combat experience. "I have often heard folks say that now is not the time to
discuss the use of force or the decision to send our men and women to fight," said
Crow. "I heard that in 2003 when I was carrying a rifle in Baghdad. I heard it again
in 2004 and 2005 when I was leading my unit through the mountains of
Afghanistan. And I am hearing it again today in the halls of Congress. In the last 19
years, more than 7,000 Americans have given their lives in these conflicts, 53,000
have been wounded and we have spent over $4 trillion dollars of taxpayer money.
"Do not believe the fearmongering," Crow concluded. "I may have laid down
my rifle, but my oath to this country endures. I will fight to ensure that we are
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=== Page 5 ===
having a discussion about when to send our men and women, our sons and
daughters, our sisters and brothers, into harm's way."
Pelosi on Iran: 'We must avoid war'
-- Slotkin left her Pentagon job to move home to Michigan after Trump took
office. Then she toppled a longtime GOP incumbent the next year in the
midterms. She faces a tough reelection battle this fall in a district Trump
carried comfortably in 2016. The National Republican Congressional Committee
has taken to calling her "pro-Iran Slotkin" in news releases. "Sit down, Elissa," one
missive from the House GOP campaign arm said this week.
Rep. Liz Cheney (R-Wyo.), the former vice president's daughter, called into a
news talk radio station in Slotkin's district on Thursday morning to attack her
for the "appalling" resolution, which she said "will send a message to the
Iranians that the country is not united behind the president." Cheney told
WILS in Lansing, Mich., that Slotkin's resolution showed "there's a big difference
between what she's saying at home and what she does when she gets here to
Washington."
In a speech on the House floor before the vote on resolution, Slotkin pushed
back forcefully on these criticisms. "Soleimani was the lead architect of much of
Iran's destabilizing activities in the Middle East and throughout the world," she said.
"To that end, with Iran, or with any other adversary, the United States always has
the inherent right and obligation to self-defense against imminent armed attacks.
Always!"
Slotkin lamented that the country has been at war for nearly two decades,
but Congress has only voted twice in that time to authorize the use of
military force: in 2001 and 2002. Rep. Barbara Lee (D-Calif.) was the lone
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=== Page 6 ===
member of Congress to vote against the authorization for the use of military force
immediately after the 9/11 attacks, which is still being cited more than 18 years
later as a legal rationale for U.S. activities in the Middle East. Only 1 in 4 House
members today were in Congress back then.
That 2001 authorization has been cited dozens of times, by three different
presidents now, to justify deploying American troops to a list of countries
that includes Libya, Turkey, Georgia, Syria, Iraq, Afghanistan, Yemen, Eritrea,
Ethiopia, Djibouti, Somalia, Kenya, the Philippines and Cuba. The language of
Slotkin's nonbinding resolution instructs Trump "to terminate the use of United
States Armed Forces to engage in hostilities in or against Iran or any part of its
government or military" unless Congress either formally declares war or there is
"an imminent armed attack upon the United States."
"When it comes to the matter of longer-term war, we have a constitutional
responsibility to authorize the use of military force," Slotkin reasoned. "The
framers of our Constitution rightly believed that the power to declare war belongs in
the Congress because this would ensure that the American people, through the
legislators they elected, would weigh the most significant decision a government
can make."
Rep. Matt Gaetz (R-Fla.) walks in the Capitol after casting his
vote on the House floor. (Matt Rourke/AP)
Rep. Matt Gaetz (R-Fla.) walks in the Capitol after casting his vote on the House floor. (Matt
Rourke/AP)
-- Slotkin's resolution passed 224 to 194, with the support of three
Republicans plus independent Justin Amash of Michigan and the opposition
of eight Democrats. The most notable vote for the resolution came from Rep.
Matt Gaetz, one of Trump's most outspoken allies on Capitol Hill. "I take a
back seat to no member of this body when it comes to defending the president," he
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=== Page 7 ===
said in a floor speech shortly before the vote. "This resolution offers no criticism of
the president. It doesn't criticize the president's attacks on Soleimani. As a matter
of fact, this resolution doesn't even say Soleimani's name in it."
Gaetz's district includes the naval air station in Pensacola, Fla. "I represent more
troops than any other member of this body," he said. "I buried one of them earlier
today at Arlington, and that sergeant died a patriot and a hero. If the members of
our armed services have the courage to go fight and die in these wars, as
Congress we ought to have the courage to vote for them or against them. It's
ludicrous to suggest that we are impairing the troops from doing their job by not
doing our job articulated in the Constitution."
The other Republicans who voted for Slotkin's resolution were Rep. Francis
Rooney (Fla.), who is retiring, and Rep. Tom Massie (Ky.), a libertarian-minded
iconoclast.
Two of the eight Democrats who voted against it are freshmen who served in
the armed forces: Reps. Elaine Luria (Va.) and Max Rose (N.Y.). And Rep.
Stephanie Murphy (Fla.) was formerly a national security specialist at the Defense
Department. The others who voted no are moderates from difficult-to-win districts,
including Ben McAdams (Utah), Anthony Brindisi (N.Y.), Joe Cunningham (S.C.),
Kendra Horn (Okla.) and Josh Gottheimer (N.J.).
Trump trashes Adam Schiff during Ohio rally
-- Trump ripped the Slotkin resolution during a rally last night in Toledo,
Ohio, insisting he doesn't need to get permission from Congress to protect
America. "[Soleimani] was a bloodthirsty terrorist and he's no longer a terrorist.
He's dead, and yet now I see the radical-left Democrats have expressed outrage
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=== Page 8 ===
over the termination of this horrible terrorist," the president said. "Instead, they
should be outraged by Soleimani's savage crimes and the fact that his countless
victims were denied justice for so long."
Trump singled out Rep. Adam Schiff (D-Calif.), who as the leader of the
House Intelligence Committee,is a member of the Gang of Eight that's
entitled to briefings on the nation's biggest secrets. Schiff spearheaded the
investigation that led to Trump's impeachment for abuse of power and obstruction
of Congress, and the congressman has clearly gotten under the president's skin.
"You little pencil neck," Trump said, referring to Schiff. Trump claimed, with no
evidence whatsoever, that Schiff would have called CNN ahead of the drone strike
on Soleimani to tip them off and that this would have allowed the Quds Force
commander to get away. "They want us to tell them so that they can leak it to their
friends in the corrupt media," he said, referring to House Democrats.
Slotkin's resolution explicitly makes an exception for defending against "an
imminent armed attack," but Trump ignored this as he complained about
Democrats trying to stop him from taking action if there's an imminent threat.
"He was looking very seriously at our embassies and not just the embassy in
Baghdad, but we stopped him very quickly and we stopped him cold," the president
told a crowd of nearly 8,000 supporters, referring to Soleimani. "We didn't have
time to call up Nancy [Pelosi], who is not operating with a full deck."
QUOTE OF THE DAY:
"It's not about how bad they are. It's about how good we are," Pelosi said
at her weekly news conference, referring to Iran and Soleimani. (Felicia
Sonmez)
Sen. Tim Kaine (D-Va.) heads to the Senate floor for a vote.
(Shawn Thew/EPA-EFE/Shutterstock)
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=== Page 9 ===
Sen. Tim Kaine (D-Va.) heads to the Senate floor for a vote. (Shawn Thew/EPA-EFE/Shutterstock)
-- In the Senate, two Republicans have committed to support Kaine's
resolution: Sens. Mike Lee (Utah) and Rand Paul (Ky.). Kaine is trying to woo
at least two more GOP colleagues by offering to make amendments that
could get them on board. He's actively discussing draft text with Sens. Susan
Collins (Maine) and Todd Young (Ind.). Kaine has already agreed to remove any
references to Trump by name to make it more palatable for Republican colleagues,
and he's willing to make more edits. "It doesn't mean everyone I talk to will get on
board, but me sitting down with them and talking them through why I've done it this
way, it gives them some level of comfort," Kaine told Jenna Portnoy.
Kaine vocally pushed to get Congress to authorize the use of military force in the
Middle East even when his good friend Barack Obama was president. (Read my
piece about it from 2015 here). In fact, Kaine refused to modulate his position even
when Hillary Clinton chose him as her running mate. His longtime emphasis on this
issue undermines the GOP argument that his resolution is politically motivated.
Keep an eye on Young, who happens to be chairman of the National Republican
Senatorial Committee. I wrote a Big Idea in May about how Young's military service
prompted him to focus on this issue when it looked like the United States might get
drawn into a war with Venezuela.
"I understand - as a former Marine Corps intelligence officer - the real-world
limitations to and the sensitivities associated with sharing certain information, even
with members of Congress," Young told Seung Min Kim, referring to the closed-
door briefing on Wednesday that left Lee and Paul seething. "But I left there feeling
as though it would've been a lot more helpful had I gotten a little peek into some of
the intel that informed the operational decisions."
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=== Page 10 ===
U.S. believes Ukraine airliner shot down by Iran
THE LATEST ON THE IRAN CRISIS:
-- In a phone call with Secretary of State Mike Pompeo, Iraqi Prime Minister
Adel Abdul Mahdi asked the United States to send a delegation to Iraq to set
up a mechanism for the "safe withdrawal of forces from Iraq." Sarah Dadouch
reports: "The Iraqi prime minister has repeatedly insisted that U.S. troop withdrawal
was the only path toward de-escalation. According to a statement, Abdul Mahdi
also shared his objections regarding U.S. forces entering Iraq and American
aircraft flying in Iraqi airspace without the consent of the Iraqi government."
-- The Trump administration hit Iran with more sanctions Friday in the first
concrete response to the attacks on U.S. forces in Iraq this week. (Carol
Morello)
-- Western officials believe an Iranian missile hit the Ukrainian plane that
crashed near Tehran earlier this week in a possible unintentional firing.
Ukraine's Volodymyr Zelensky is now asking Western leaders to share with
him the intelligence that suggests this. Isabelle Khurshudyan and Erin
Cunningham report: "Iran, meanwhile, denied the assertions that the Boeing 737,
carrying 176 people from Tehran to Kyiv, was shot down early Wednesday shortly
after departing from Tehran. Ukraine has taken an active role in investigating the
crash of the jet, which was carrying 11 Ukrainians, including the crew. A team of 45
experts and search-and-rescue personnel from Ukraine, including specialists who
helped investigate the July 2014 downing of Malaysia Airlines Flight 17 over
Ukrainian territory, arrived in Tehran early Thursday to participate in the probe.
Zelensky had phone conversations Thursday with heads of government from
Canada, Britain, Sweden and Iran - countries that each had citizens among the
passengers. While Ukraine's readouts of those calls said Zelensky intended to
keep the leaders abreast of Ukraine's findings and encouraged their
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=== Page 11 ===
countries to participate in the investigation, he has now had to publicly ask
to be briefed in return. The Ukrainian leader is expected to speak with
[Pompeo] on Friday.
"In Washington, U.S. officials expressed 'high confidence' that the Boeing
737-800 was targeted by an SA-15 surface-to-air missile, part of a Russian-
made air defense system also known as a Tor system, as Iranian forces were on
high alert. President Trump said the downing of the aircraft was probably a
'mistake.' Then in Ottawa, Canadian Prime Minister Justin Trudeau said
intelligence analyses indicated that a surface-to-air missile hit the plane in what
could have been an 'unintentional' act. A Ukrainian official said that Zelensky
made the public request for evidence about the crash because the United
States had not yet shared with Ukraine its intelligence about the missile
Thursday.
"The Washington Post obtained a video that allegedly shows the moment the
airliner was struck in midair. The video, first published by the New York
Times, purportedly shows a missile intercepting the aircraft near the city of
Parand, followed by a loud boom. Earlier Friday, the Iranian government said
in a statement that it was inviting Boeing to send a representative to help examine
the 'black box' containing the flight data and cockpit voice recorders. Iranian state
television aired a video of an investigator opening and showing the contents of the
box."
-- The tragedy mirrors the 1988 Iran Air incident, in which a passenger plane
that had originated in the Iranian capital was shot down, leaving 290
dead. Adam Taylor reports: "On July 3, 1988, Iran Air Flight 655 was shot down by
the U.S. military. The flight was flying over the Strait of Hormuz toward its
destination, Dubai, when it was hit by two surface-to-air missiles. Though Pentagon
officials at first denied any knowledge of the incident, it soon emerged that the
plane had been targeted by the USS Vincennes, a cruiser that had been involved
in a skirmish with Iranian boats in the Persian Gulf and had mistaken the
EFTA00032528

=== Page 12 ===
passenger jet for an Iranian warplane. President Ronald Reagan expressed
sympathy for the 'terrible human tragedy' but suggested that the plane had 'failed
to heed repeated warnings.' However, an investigation by the International Civil
Aviation Organization, a U.N. agency, found that U.S. military ships in the region
did not have the equipment necessary to monitor civilian air-traffic-control
frequencies."
-- On Fox News last night, Pompeo reiterated that Soleimani planned "a series
of imminent attacks." Asked for specifics, he added: "We don't know precisely
when and we don't know precisely where. But it was real."
-- An Iranian military commander said the missiles fired at bases used by
U.S. troops in Iraq were not intended to inflict casualties. Kareem Fahim and
Sarah Dadouch report: "We did not intend to kill,' said Brig. Gen. Amir Ali
Hajizadeh, the head of the Revolutionary Guard's Aerospace Force, according to
Iranian state media. 'We intended to hit the enemy's military machinery.' However,
he repeated the government's claim that 'tens of people were killed or wounded.'
U.S. and Iraqi officials said the strikes caused no casualties. Iran tried to counter
the United States on the diplomatic front Thursday after Trump called on Britain,
Germany, France, Russia and China to 'break away from the remnants' of the 2015
nuclear deal Iran struck with world powers. British Prime Minister Boris Johnson,
speaking with Iranian President Hassan Rouhani on Thursday, 'underlined the UK's
continued commitment to' the nuclear deal and 'ongoing dialogue to avoid nuclear
proliferation and reduce tensions,' according to a British government statement.
Rouhani also called European Council President Charles Michel asking for a
response to U.S. sanctions, which Rouhani described as 'economic terrorism,' the
Iranian Fars News agency reported. In a statement, Michel emphasized the need
for de-escalation in the region."
-- The U.S. strike on Soleimani's convoy last week also killed Abu Mahdi al-
Muhandis, the deputy head of an Iraqi paramilitary group, whose death could
have far-reaching implications. From Middle East Eye: "Commanders of Iranian-
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=== Page 13 ===
backed armed factions in Iraq tell MEE that with the loss of the two leaders, they
are now almost paralysed and would be unable to strike the Americans with real
consequence. Muhandis, who since the 1980s has been one of America's most
wanted men over his involvement in the bombing of the US and French embassies
in Kuwait, was seen by most Iraqis as Iran's most influential man in the country.
Although formally stripped of his financial and administrative powers, Muhandis
continued to enjoy great influence over most of the Hashd al-Shaabi's armed
factions, with the government unable to regain control over the paramilitary
umbrella group or force Muhandis to implement orders for fear of retaliation,
While he frustrated the government, it was Muhandis' strong personality, and his
blatant challenge to it and the rest of his opponents, that so attracted the leaders
and fighters of the armed factions and kept them revolving around him like moths
to a flame, following wherever he went."
-- The speed at which the Iran crisis unfolded shows the influence Trump's
new team of national security advisers has. From the Journal: "The group,
including new Secretary of Defense Mark Esper, new chairman of the Joint Chiefs
of Staff Mark Milley and new national security adviser Robert O'Brien, along with
[Pompeo], backed the president's decision to kill the top Iranian military
commander and moved swiftly to carry it out. The new team was cohesive and less
inclined than its predecessors to push back against the president's wishes,
according to administration officials and others consulted by the White House.
They also were less likely to consult in advance with other administration,
Pentagon or State Department officials, congressional leaders or foreign allies,
some of these officials said."
-- Informants in Iraq and Syria helped the United States kill Soleimani. From
Reuters: "Soleimani arrived at the Damascus airport in a vehicle with dark-tinted
glass. They parked near a staircase leading to a Cham Wings Airbus A320,
destined for Baghdad. Neither Soleimani nor the soldiers were registered on the
passenger manifesto. The passenger flight would be Soleimani's last.
EFTA00032530

=== Page 14 ===
Investigators have focused on how suspected informants inside the Damascus and
Baghdad airports collaborated with the U.S. military to help track and pinpoint
Soleimani's position. The suspects include two security staffers at the Baghdad
airport and two Cham Wings employees. The National Security agency's
investigators believe the four suspects, who have not been arrested, worked as
part of a wider group of people feeding information to the U.S. military, the official
said."
-- For Trump and Iran, Twitter trolling helped escalate tensions on the
battlefield. David Nakamura reports: "A day after [Trump] signaled he would not
use military force to escalate a tense standoff with Iran, that nation's supreme
leader responded with a message of his own: a doctored photo of Trump's face
imprinted with red welts from a slap to the face. The creation on the official website
of Ayatollah Ali Khamenei offered a trolling visual meme to echo his previous
warning that Tehran's missile attack on two Iraqi facilities housing U.S. troops was
only the first salvo in a campaign to avenge the drone killing of [Soleimani.]
Experts called the display an example of a new era in international diplomacy in
which official letters, telephone hotlines and secure video conference calls have
been replaced, in some cases, by high-octane and instantaneous social media
messaging."
-- Notable commentary from The Post's opinion page:
Jim Webb, former Democratic senator from Virginia and
secretary of the Navy under Reagan: "When did it become
acceptable to kill a top leader of a country we aren't even at war
with?"
Andrew McCabe, former deputy director of the FBI: "If you think
Iran is done retaliating, think again."
Fareed Zakaria: "Trump does not have a foreign policy. He has
a series of impulses."
EFTA00032531

=== Page 15 ===
David Ignatius: "This is what a real Iran strategy would look
like."
Eugene Robinson: "The best Iran crisis explanation? Trump's
obsession with Obama."
Josh Rogin: "Soleimani's death offers a chance to fix U.S. policy
on Syria."
Max Boot: "By claiming Democrats support terrorism,
Republicans hit a new low."
A hilarious satire by Alexandra Petri: "Millions of Americans
devastated to learn they were ardent fans of Soleimani this
whole time."
The Daily 202's BIG IDEA > Get James' insight into Washington every weekday on your
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Why Democrats say they're withholding the impeachment articles
DOMESTIC DEVELOPMENTS THAT SHOULDN'T BE OVERSHADOWED:
-- Nancy Pelosi signaled this morning in a letter to colleagues that the House
will transmit the articles of impeachment to the Senate as soon as next week.
"I have asked Judiciary Committee Chairman Jerry Nadler to be prepared to bring
to the Floor next week a resolution to appoint managers and transmit articles of
impeachment to the Senate," she wrote. (Our live blog has more.)
EFTA00032532

=== Page 16 ===
-- The Senate has conducted 15 impeachment trials in U.S. history. It has
heard witnesses in every single one. Noah Bookbinder, executive director of
Citizens for Responsibility and Ethics in Washington, reviews the history: "Only 19
other individuals besides Trump have been impeached by the House of
Representatives. The Senate completed a trial in 15 of those cases, and in every
single one of them, it heard testimony from witnesses. Those cases include the
only two prior instances in which a president was impeached."
-- House Republicans are eyeing a push to condemn Pelosi for delaying the
trial. From Politico: "GOP Rep. Bradley Byrne, who is running for an Alabama
Senate seat, introduced a censure resolution on Thursday morning to rebuke
Pelosi for hanging on to the articles of impeachment since December. Republicans
have the option to force a floor vote on the measure though Democrats would
surely move to table it, just as they did with a censure resolution against" Schiff.
-- Meanwhile, Rep. Elise Stefanik (R-N.Y.) tweeted an impeachment-related
fundraising appeal that included a doctored photo of Pelosi, drawing a
retweet from Trump. Felicia Sonmez reports: "The tweet marks the second time
this week that a House Republican has tweeted a photo that appears to have been
manipulated. On Monday, Rep. Paul Gosar (R-Ariz.) tweeted a fake photo of
Obama with Iranian President Hassan Rouhani. The tweet shows a close-up,
red-tinted photo of Pelosi, with the lines in the House speaker's face exaggerated
due to the image's unnaturally high contrast."
Matt Golsteyn is pictured in his D.C. office with his wife Julie and
their infant son Henry. (Sarah L. Voisin/The Washington Post)
Matt Golsteyn is pictured in his D.C. office with his wife Julie and their infant son Henry. (Sarah L.
Voisin/The Washington Post)
-- An Army general denied a request by an officer pardoned by Trump in an
open murder case to have his Special Forces tab reinstated. Dan Lamothe
EFTA00032533

=== Page 17 ===
reports: "The decoration for retired Army Maj. Mathew L. Golsteyn was denied Dec.
3 by Lt. Gen. Francis M. Beaudette, the commander of U.S. Army Special
Operations Command, the Army disclosed Thursday. Beaudette's decision is not
final, and the service said in a statement that it will next have an administrative
panel consider whether it should reinstate the Special Forces tab and a
Distinguished Service Cross - the U.S. military's second-highest valor award -
and expunge a letter of reprimand Golsteyn received in connection with his case.
Golsteyn was awaiting trial this year in the alleged murder of a suspected Taliban
bombmaker in Marja, Afghanistan, in February 2010. The general's denial of
Golsteyn's reinstatement request follows Trump's decision in November to pardon
Golsteyn along with former 1st Lt. Clint Lorance, an Army officer who had been
convicted of murder in Afghanistan.
Golsteyn, reached for comment Thursday
evening, said he had not heard about the decision until it was first reported by The
Washington Post. A few minutes later, he and his lawyer, Phil Stackhouse, said
they received notification from the Army in an emailed letter that had just arrived."
-- The Justice Department is winding down the Hillary Clinton-related inquiry
once championed by Trump. It found nothing of consequence. Devlin Barrett
and Matt Zapotosky report: "John Huber, the U.S. attorney in Utah, was tapped in
November 2017 by then-Attorney General Jeff Sessions to look into concerns
raised by Trump and his allies in Congress that the FBI had not fully pursued cases
of possible corruption at the Clinton Foundation and during Clinton's time as
secretary of state, when the U.S. government decided not to block the sale of a
company called Uranium One. As a part of his review, Huber examined documents
and conferred with federal law enforcement officials in Little Rock who were
handling a meandering probe into the Clinton Foundation. Current and former
officials said that Huber has largely finished and found nothing worth pursuing -
though the assignment has not formally ended and no official notice has been sent
to the Justice Department or to lawmakers."
EFTA00032534

=== Page 18 ===
-- Internal Boeing documents show employees discussing efforts to
manipulate U.S. and international safety regulators. lan Duncan, Lori Aratani
and Michael Laris report: "Yes, I still haven't been forgiven by god for the covering
up I did last year," said a 2018 message. Another exchange between Boeing
employees, from August 2015, closes out with this: 'I know but this is what these
regulators get when they try and get in the way. they impede progress. In 2017,
a Boeing employee wrote: 'this airplane is designed by clowns, who in turn
are supervised by monkeys.' The documents were released by Boeing to
congressional investigators probing how the company's 737 Max jets were certified
by the Federal Aviation Administration as safe before two crashes that killed 346
people.
"At issue in some of the messages was whether simulator training should be
required for pilots flying the Max. Boeing went to great lengths to prevent
such a requirement, in part because it would be costly for its customers,
company documents show. In one November 2015 message, the 737 chief
technical pilot, whose name is redacted in the documents, said failing to get
computer-based training for one system 'is a planet-killer for the MAX.' In
another email chain, from June 2017, the chief technical pilot forwarded to Boeing
colleagues messages in which he persuaded an airline, which is not identified in
the documents, not to require simulator training on the Max. 'Looks like my jedi
mind trick worked again!' the pilot wrote. 'These are not the droids you're looking
for.' In a shift Tuesday, the company said that it is recommending that pilots
undergo simulator training before they resume flying the 737 Max. The FAA, which
will have the final say, said it will consider Boeing's recommendation." (Read the
Boeing documents for yourself here.)
-- The United States economy added 145,000 jobs in December as the
unemployment rate remained at 3.5 percent. (Rachel Siegel)
-- Video from Jeffrey Epstein's first apparent suicide attempt was lost due to
"technical errors," according to prosecutors. Reis Thebault reports: "Federal
EFTA00032535

=== Page 19 ===
prosecutors said in December they were unable to locate the video, which would
have showed guards finding Epstein after his first apparent suicide attempt in July.
Then, just a day later, they wrote in a court filing that they had found the footage
and were 'in the process of obtaining a copy' from the Metropolitan Correctional
Center in New York City, where Epstein was held. But on Thursday, prosecutors
reversed themselves again, saying the video 'no longer exists' because of
'technical errors.' Jail officials initially thought they had saved footage from outside
Epstein's cell, when in fact the footage they preserved was from a different part of
the facility, explained Assistant U.S. Attorneys
and Jason
Swergold in the latest filing."
-- Border crossings are starting to plateau as U.S. officials report a continued
decline in immigration apprehensions. Abigail Hauslohner reports: "The number
of people apprehended or deemed 'inadmissible' by U.S. border authorities along
the southern border fell to 40,620 last month, down 72 percent from May, when the
Trump administration declared it was at the height of a border crisis. December
marked the seventh straight month of decline in border crossings, but the month-
to-month differences have shrunk significantly since September. Border
enforcement actions last month were roughly on par with December 2017."
-- Counties, cities and states are stepping up on their climate goals as the
Trump administration steps back. Rebecca Tan reports: "Maryland's most
populous jurisdiction is promising an ambitious package of new climate initiatives in
2020, joining other liberal counties, cities and states stepping up to address what
they see as the Trump administration's resistance to protecting the planet. In
February, Montgomery will hold a town hall on hundreds of recommendations from
climate workgroups convened last year by County Executive Marc Elrich (D). And
by early 2021, officials hope to unveil a comprehensive plan detailing how the
county will reduce greenhouse gas emissions by 80 percent by 2027 and 100
percent by 2035."
EFTA00032536

=== Page 20 ===
American sprinters Tommie Smith (center) and John Carlos (right)
raise their gloved fists in a civil rights protest at the 1968 Olympic
Games in Mexico City. (AP)&nbsp;
American sprinters Tommie Smith (center) and John Carlos (right) raise their gloved fists in a civil
rights protest at the 1968 Olympic Games in Mexico City. (AP)
THE NEW WORLD ORDER:
-- Gag rule alert: The International Olympic Committee warned athletes they
would face sanctions, which could include the loss of medals, for
participating in political protests during the Olympics in Tokyo this summer,
including kneeling, political hand gestures and wearing or holding signs or
armbands. Jacob Bogage reports: "The committee published a three-page
document of guidelines. 'We needed clarity, and they wanted clarity on the
rules,' [said] Kirsty Coventry of Zimbabwe, chair of the IOC Athletes' Commission,
which helped create the new document. The guidelines outlaw demonstrations
such as those staged by Tommie Smith and John Carlos, American sprinters who
raised their gloved fists on the medal stand at the 1968 Games in Mexico City, and
former NFL player Colin Kaepernick, who in 2016 began kneeling during the
national anthem. Both demonstrations sought to draw attention to racial injustice
and have been repeated by other athletes in recent years.
"Ethiopian runner Feyisa Lilesa crossed his wrists at the finish line of the
men's marathon at the 2016 Games in Rio de Janeiro to show support for
civil rights protesters in his home country. Americans Race Imboden, a fencer,
and hammer-thrower Gwen Berry were placed on probation by the U.S. Olympic
and Paralympic Committee in August after demonstrating on the medal stand at
the Pan American Games. Imboden knelt during the national anthem, while Berry
raised a fist. Athletes who protest will face discipline 'on a case-by-case basis as
necessary,' according to the guidelines."
EFTA00032537

=== Page 21 ===
-- A billion animals have been caught in Australia's fires. Some may go
extinct. Karin Brulliard and Darryl Fears report: "The mouse-size dunnart is not as
iconic as the koalas or platypuses that draw tourists, but it is arguably the most
special mammal on Australia's Kangaroo Island. Now the Kangaroo Island
dunnart's days may be numbered. Before bush fires struck, it was already
endangered, so rare that even researchers who studied them had never seen one.
Now they fear they never will. One-third of the 1,700-square-mile island has
burned, including the entire area where these dunnarts are known to live. More
than 1 billion mammals, birds and reptiles nationwide - some of them found
nowhere else on Earth - may have been affected or killed by the fires sweeping
across Australia, according to a University of Sydney estimate. The potential toll is
far greater when other types of animals are included. Individual animals might
survive, but when their habitat is gone, 'it doesn't matter,' Saunders said. 'They'll
die anyway."
-- Disgusting: Hoaxers are using the fires to spread misinformation and
profit, Brittany Shammas reports.
-- The fire crisis is fueling protests calling for bolder action on climate
change. Kate Shuttleworth reports: "At rallies nationwide on Friday, thousands
called for Prime Minister Scott Morrison to resign over what they say is his
administration's passivity on an issue that has hit home to millions of Australians as
a clear and present danger. The conservative leader has defended his disaster
response after facing criticism from victims and firefighters for its perceived
inadequacy. In Melbourne, close to 10,000 people took to the streets, spurning
calls from police and the state's center-left leader, Daniel Andrews, not to risk
diverting emergency resources. An organizer of a similar rally in Sydney, Gavin
Stanbrook, said the events of recent weeks revealed a nation polarized over how
to tackle the challenge. 'We are divided between coal interests and politicians on
the one side and then firefighters and volunteers on the other and the rest of us
who are either impacted or our friends and family are on the front line, or in cities
EFTA00032538

=== Page 22 ===
surrounded by smoke,' Stanbrook said. 'We need to come together and say that
we will not accept it anymore."
-- Suspected Islamist militants killed 25 soldiers in Niger. Danielle Paquette
reports: "The clash unfolded in the western village of Chinegodar near the border
with Mali, according to Nigerien defense officials, as fighters with ties to the Islamic
State and al-Qaeda look to seize new swaths of territory. The bloodshed came
about a month after gunmen ambushed a Nigerien army post in another border
town, killing 71 soldiers in the deadliest strike on the nation's forces in recent
memory. The Islamic State West Africa Province asserted responsibility for that
massacre two days later."
-- In Israel, deadly floods have kept residents confined to their homes and
offices even as they braced for potential spinoff attacks from rising tensions
between the United States and Iran. Steve Hendrix reports: "Prime Minister
Benjamin Netanyahu on Thursday beseeched citizens to take flood warnings as
seriously as they do the sirens warning of imminent rocket fire that are a feature of
life in many Israeli communities. Netanyahu also warned the adventurous not to
venture out to the desert to witness the dramatic - and potentially dangerous -
spectacle of dry stream beds reanimated with roaring water. 'Watch them on
television,' he advised. Officials said rescue resources had been redeployed
nationwide in response to the flooding, which stretched from the coastal plains
along the Mediterranean to the occupied West Bank down to the Dead Sea."
-- China identified a new strain of coronavirus as the source of its
pneumonia outbreak. Gerry Shih and Lena H. Sun report: "A group of Chinese
experts this week isolated and obtained the genome sequence of the new virus,
which is believed to be responsible for sickening dozens of people who visited a
wild-animal market last month in Wuhan, in central China, state media reported
Thursday. The outbreak ahead of the Lunar New Year travel season in China has
prompted health authorities across East Asia to increase screening of travelers for
signs of fever, underscoring fears about its potential spread."
EFTA00032539

=== Page 23 ===
-- Understatement of the year? Pope Francis said 2020 is off to a rough start,
saying it "does not seem to be marked by encouraging signs." Chico Harlan
reports: "While saying that maintaining hope is essential, the pope spent the next
45 minutes talking about wars and could-be wars, exploitation, sexual abuse,
Internet hate speech, international indifference to humanitarian crises, and the
depressing state of the world's fight against climate change. He called heightened
tensions between the United States and Iran 'particularly troubling,' but his remarks
amounted to a laundry list of flash points, both major and obscure, from Burkina
Faso to Venezuela to Australia. 'Certainly, hope has to be realistic,' Francis said. 'It
demands acknowledging the many troubling issues confronting our world and the
challenges lurking on the horizon. It requires that problems be called by their name
and the courage be found to resolve them."
-- Lebanon has banned ex-Nissan chief Carlos Ghosn from traveling. Sarah
Dadouch reports: "Ghosn appeared at a hearing in Lebanon on Thursday, two days
after Lebanon's caretaker justice minister, Albert Serhan, said the country's public
prosecutor had received the Interpol red notice about Ghosn and would be taking
the necessary steps. He was placed under house arrest. A few days after his
arrival in Lebanon's capital, Ghosn found himself in more legal trouble: A group of
lawyers last Thursday lodged a legal complaint against him for visiting Israel as
chairman of Renault and later Nissan. Lebanon and Israel have been in a state of
war for the past six decades, and Lebanese law considers interacting with the
country's southern neighbor and sworn enemy a crime. Ali Abbas, one of the two
lawyers who filed the Israel-related complaint against Ghosn, said the travel ban
was a formality that usually comes after receiving Interpol notices, especially red
notices, which alert police about internationally wanted fugitives but do not compel
any country to arrest the fugitive."
-- Trump wished North Korean leader Kim Jung Un a happy birthday through
South Korea. (AP)
EFTA00032540

=== Page 24 ===
-- A statue mocking Trump in Melania Trump's home country was burned
down. Lateshia Beachum reports: "Firefighters in Moravce, a city in central
Slovenia, tried to extinguish the bonfire, but their efforts left charred planks on the
ground. The arsonists responsible for the Christmas nutcracker-like statue's ashes
are reportedly still at large. The nearly 26-foot tall wooden structure that had a
mechanism to open Trump's red painted mouth full of pointy teeth was constructed
last year in a nation divided over the U.S. president. The statue of Trump, with the
president's signature blue suit and red tie, had been under torch threats since local
residents threatened to set it ablaze on Halloween It was relocated because of
the risk."
-- London's Madame Tussauds removed its wax figures of Prince Harry and
Meghan, Duchess of Sussex, from its display of Britain's royal family less
than 24 hours after the couple announced they would be "stepping back"
from their roles as senior royals. Jennifer Hassan reports: "The figures will no
longer stand alongside the rest of the royal family. They have been moved by the
wax museum's staff. The likenesses of the Duke and Duchess of Cambridge,
William and Catherine, remain on display alongside figures of Queen Elizabeth Il
and her husband, Prince Philip. 'As two of our most popular and well-loved figures,
they will of course remain an important feature at Madame Tussauds London as
we watch to see what the next chapter holds for them,' said [Steve Davies, general
manager of Madame Tussauds London]."
Vice President Pence, along with White House senior adviser
Jared Kushner and his wife, Ivanka Trump, and their children,
Arabella, Joseph and Theodore Kushner, attend a Hanukkah
reception in the East Room of the White House last month. (Manuel
Balce Ceneta/AP)
Vice President Pence, along with White House senior adviser Jared Kushner and his wife, Ivanka
Trump, and their children, Arabella, Joseph and Theodore Kushner, attend a Hanukkah reception in
the East Room of the White House last month. (Manuel Balce Ceneta/AP)
EFTA00032541

=== Page 25 ===
2020 WATCH:
-- Jared Kushner's global role is shrinking as his role in the president's
reelection campaign grows. From Annie Karni and Maggie Haberman in the
Times: "When senior administration officials gathered in the Situation Room on
Tuesday for a meeting to discuss the repercussions of the killing of [Soleimani], the
White House aide whose portfolio is the Middle East was notably absent from the
meeting. [He] was sitting for a photo shoot for a planned Time magazine cover
story. [Kushner] is positioning himself to be the overseer of something of even
greater personal interest to his father-in-law: Mr. Trump's 2020 re-election
campaign. [Kushner] sees no reason to involve himself as extensively in
international issues now that the State Department is run by [Mike] Pompeo, whom
he sees as far more competent than his predecessor, Rex W. Tillerson."
-- Mike Bloomberg won't release the women who sued him from their
nondisclosure agreements. From ABC News: "You can't just walk away from it,'
Bloomberg said. 'They're legal agreements, and for all I know the other side
wouldn't want to get out of it.' Last month, ABC News reported on several lawsuits
in which Bloomberg was accused of making crude remarks in the 1990s and
of allegedly fostering an uncomfortable environment for women to work -
allegations Bloomberg has denied. Three cases against the company remain
active. ABC News has spoken with several women who expressed interest in
telling their stories who were subject to confidentiality agreements, but said they
feared the prospect of facing retribution from the company for speaking out."
-- Tom Steyer appears to have qualified for the seventh Democratic debate,
scheduled for next Tuesday night in lowa, on the strength of Fox News polls
that found him with double-digit support in Nevada and South Carolina. David
Weigel reports: "Steyer, who has spent more than $115 million on his campaign so
far, hit 12 percent in the network's poll of Nevada and 15 percent in South
Carolina. It came after Steyer poured more than $20 million into commercials
and other advertising in these states as of this week, with $11.2 million worth of
EFTA00032542

=== Page 26 ===
expenditures in South Carolina and $10.3 million in Nevada. He has also spent
heavily to attract hundreds of thousands of small-dollar donations, which the DNC
requires for debate access."
-- The Fox News Nevada poll also shows Joe Biden and Bernie Sanders
vying for the lead in the state: "Biden tops Sanders by 23-17 percent among
Democratic caucusgoers, with both down one percentage point since November.
[Elizabeth] Warren comes in at 12 percent, down from 18 percent - and ties with
[Steyer] for third."
-- A new Monmouth Poll shows a four-way fight in the New Hampshire
Democratic primary: "Among registered New Hampshire Democrats and
unaffiliated voters who are likely to participate in the February 2020 Democratic
primary, 20% currently support [Pete] Buttigieg, 19% back Biden, 18% back
Sanders, and 15% back Warren. Compared to Monmouth's last New Hampshire
poll in September, Buttigieg's support has grown by 10 points (from 10%) and
Sanders' support has increased by 6 points (from 12%). Warren's support has
dropped by 12 points (from 27%) and Biden's has decreased by 6 points (from
25%)."
-- Los Angeles Mayor Eric Garcetti endorsed Biden. From the Los Angeles
Times: "Garcetti will be one of Biden's highest-profile supporters in California's
March 3 primary, but the endorsement is unlikely to have any practical effect on the
highly competitive race. Dianne Feinstein, the state's senior U.S. senator, is also
supporting Biden. And Long Beach Mayor Robert Garcia, who had endorsed
California Sen. Kamala Harris before she dropped out of the presidential race, also
announced his support for Biden on Thursday."
-- Fun read: Philadelphians looking for love on Tinder may have come across
"Daddy Bernie," a profile set up for Sanders by a local man who just wants to
inform people on the dating app about his favorite candidate. From the
Philadelphia Inquirer: "Alex Scheinberg, 26, is not a senator from Vermont. Or any
EFTA00032543

=== Page 27 ===
other state. He actually doesn't have a job. And he lives in his childhood home.
But, Scheinberg said, that gives him more time to mix politics and pleasure in order
to promote his favorite candidate in a forum that's increasingly becoming a venue
for political endorsement and engagement. Scheinberg has his Tinder profile set
to see all genders and sexual orientations, though he is straight. This way, he said,
he can maximize the number of people seeing Sanders' campaign message.
That's the same reason he swipes right on almost everyone, to reach as many
people as possible. (For those who don't have to experience the horror show that
is modern online dating, swiping right on a profile means you're interested. Swiping
left, not so much.)"
SOCIAL MEDIA SPEED READ:
One of Vice President Pence's children got married at the Naval Academy over the
holidays:
A former senior adviser to Obama made this observation about the passenger
plane shot down in Iran:
A Republican senator from South Carolina had a flip response when confronted by
a protester:
An alarming number of registered voters in our country cannot even place Iran on a
map:
EFTA00032544

=== Page 28 ===
The White House press secretary turned down an offer to support a charity in
exchange for giving a news conference. In other news, irony is dead:
A Republican senator met with a Democratic colleague to talk about climate
change. Both have run unsuccessfully for president, but the Democrat's campaign
is still active:
Marianne Williamson, who is also still in the presidential race, called out the lack of
diversity among Trump's top advisers:
John Kerry joined Joe Biden in lowa:
Billionaires are making themselves heard in the presidential race:
And the House majority whip, Rep. Jim Clyburn (D-S.C.), shared a touching story
about his wife, who recently passed away:
EFTA00032545

=== Page 29 ===
VIDEOS OF THE DAY:
You received this email because you signed up for The Daily 202 or because it is included in your subscription.
Manage my email newsletters and alerts I Unsubscribe from The Daily 202
Stephen Colbert joked that he was ruining Republican Sen. Mike Lee's political
career by agreeing with him on his ofthe White House's Iran briefing:
©2020 The Washington Post 1301 K St NW, Washington DC 20071
Seth Meyers also went through Republican senators' comments of the Iran
briefing:
Trevor Noah gave an explainer on the Australian fires:
And Sen. Amy Klobuchar (D-Minn.) has an impressive party trick that the other
2020 candidates probably don't:
EFTA00032546


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=== Page 1 ===
AW
,
Inmate Epstein seems psychologically stable.
He complained that his right arm was numb and hanging earlier. Nurse
saw him.
He again said his right arm still feels somewhat numb and he said he cannot make a fist with that hand. He also said he has
numbness on his neck. I informed Nurse
He stated the toilet in his cell was running for 45 minutes last night and he could not take the noise. He is going to try the toilet before
going to legal today and if it does not shut off, he will be moved to another cell.
Thanks,
>>>
7/28/2019 7:36 AM >>>
Inmate
#20472-038 is being taken off of Psych Observation.
Suicide Watch
None
Psych Observation
1. Epstein #76318-054
Pending Bedspace for SHU
1,
#20472-038
Thank you,
CONFIDENTIAL
SDNY_00009930
EFTA00034044


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Date: Wed, 16 Jun 2021 15:58:13 +0000
Attachments:2019-02-28,_JE_letter_re_all_writs_act_application,_15_Civ_7433_(RWS).pdf;2019-02-
8,_JE_letter_re_all_writs_act_application,_17_Civ_0616_(SN).pdf
Pottinger was a lawyer at Boies Schiller who represented
, the plaintiff in the civil action.
The two letters we submitted in connection with our All Writs Application are attached.
From:
(USANYS)
Sent: Wednesday, June 16, 2021 11:53 AM
To:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Another Q: who's Stan Pottinger?
From:
(USANYS)
Sent: Wednesday, June 16, 2021 10:53 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
From:
(USANYS)
Sent: Wednesday, June 16, 2021 10:40 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S?
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:45 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
In the spirit of completeness, I'm also attaching their replies.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:20 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: Re: Question re AJN/Maxwell Suppression Hearing
EFTA00032757

=== Page 2 ===
Goodness!
Associate U.S. Attorney
Southern District of New York
On Jun 15, 2021, at 5:06 PM,
(USANYS)
wrote:
She filed 12 (!!) separate MOLs as a way to evade the Court's page limits. Defense attorneys have started doing that
over the last few years.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 4:25 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Dumb Q: why does Maxwell have two memos of law?
From:
(USANYS)
Sent: Tuesday, June 15, 2021 2:19 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the
McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our
motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial.
Thanks very much.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 10:09 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Sure, set a time other than 2:00. I'm in the office. Or Webex
From:
(USANYS)
Sent: Tuesday, June 15, 2021 9:11 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Question re AJN/Maxwell Suppression Hearing
Hi
EFTA00032758

=== Page 3 ===
We had an issue come up related to the upcoming suppression hearing (no date set yet, although we expect one)
related to Rossmiller/Kramer that we'd like your thoughts on. Let us know a convenient time to stop by over the next
few days, thanks.
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
EFTA00032759


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=== Page 1 ===
To:
From:
Sent:
Sun 7/14/2019 10:01:03 AM
Subject: Lieutenant's log and daily activity log for Saturday, July 14, 2019.
TEXT.htm
Daily Activities Report 7-13-2019.docx
LIEUTENANT'S LOG 07-13-2019.docm
Lieutenant's log and daily activity log for Saturday, July 14, 2019.
Lieutenant
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, N.Y. 10007
CONFIDENTIAL
SDNY_00008724
EFTA00033576


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Fri, 24 May 2019 20:01:08 +0000
Importance: Normal
Thanks
- have a great weekend.
From:
Sent: Friday, May 24, 2019 15:55
To:
Cc:
is
is
Subject: Re: travel approval request
All approved.
Sent from my iPad
On May 24, 2019, at 2:57 PM,
wrote:
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
EFTA00032491

=== Page 2 ===
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
)
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00032492


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=== Page 1 ===
Event: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Start Date: 2019-11-07 18:00:00 +0000
End Date: 2019-11-07 18:30:00 +0000
Organizer: Hudgens, Johanna Rae <JHudgens@winston.com>
Location:
Class: X-PERSONAL
Date Created: 2019-11-06 18:09:02 +0000
Date Modified: 2019-11-06 18:09:02 +0000
Priority: 5
DTSTAMP: 2019-11-06 17:54:42 +0000
Attendee:
>; Bloom, Suzanne Jaffe
>; Calvar, Cristina I.
is
)
i
Alarm: Display the following message 15m before start
Reminder
Telephone:
The contents of this message may be privileged and confidential. If this message has been
received in error, please delete it without reading it. Your receipt of this message is not intended
to waive any applicable privilege. Please do not disseminate this message without the
permission of the author. Any tax advice contained in this email was not intended to be used,
and cannot be used, by you (or any other taxpayer) to avoid penalties under applicable tax laws
and regulations.
EFTA00032336


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=== Page 1 ===
From:
=
(USANYS)"
To:
(USANYS)"
Subject: Accepted: Meet on Epstein
Date: Tue, 17 Sep 2019 01:33:14 +0000
Importance: Normal
Attachments: unnamed
EFTA00032440


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=== Page 1 ===
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
September 15, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
The Government expects to offer testimony from Computer Forensic Examiner Stephen
of the Federal Bureau of Investigation's ("FBI") Computer Analysis Response Team
("CART"). Although the Government believes that Examiner
testimony will not require
admission through Rule 702 of the Federal Rules of Evidence, the Government nevertheless
provides notice of Examiner
anticipated testimony in an abundance of caution. A copy
of Examiner
curriculum vitae is being produced to you today bearing Bates number 3503-
001.¹
The Government anticipates that, if called as a witness, Examiner
will testify about
his extraction of devices seized pursuant to court-authorized search warrants; user information
associated with certain of those devices; and documents and photographs extracted from certain
1 Examiner
has previously testified regarding similar topics in federal court. As a courtesy,
the Government notifies you that Examiner
has previously testified in federal court in
United States V. DiTomasso, 14 Cr. 160 (SAS), United States V. Hirst, 15 Cr. 643 (PKC), United
States V. Stasiv, 18 Cr. 259 (PKC), and United States V. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.).
EFTA00032021

=== Page 2 ===
Page 2
of those devices. The Government further anticipates that Examiner
will also testify that
some of the devices on which he performed extractions were clones of device extractions that had
previously been performed by someone else.
The Government reserves the right to call additional expert witnesses and will promptly
provide notice if the Government elects to do so.
Request for Reciprocal Discovery and Expert Notice
The Government reiterates its April 23, 2021 request for reciprocal notice under Rule
16(b)(1)(C) of the Federal Rules of Criminal Procedure regarding any expert witness that the
defendant intends to rely upon, including a written summary of any testimony that the defendant
intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence, as well as the
witness's qualifications.
Additionally, the Government reiterates its August 5, 2020 request for reciprocal discovery
under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of:
(1) any books, papers, documents, data, photographs, tangible objects, buildings or places, or
copies or portions thereof, which are in the defendant's possession, custody or control, and which
the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or
reports of physical or mental examinations and of scientific tests or experiments made in
connection with this case, or copies thereof, which are in the defendant's possession or control,
and which the defendant intends to introduce as evidence or otherwise rely on at trial or which
were prepared by a witness whom the defendant intends to call at trial.
The Government also reiterates its August 5, 2020 request that the defendant disclose prior
statements of witnesses she will call to testify, including expert witnesses. See Fed. R. Crim. P.
26.2; United States V. Nobles, 422 U.S. 225 (1975). The Government requests that such material
be provided on the same basis upon which the Government agrees to supply the defendant with
3500 material relating to Government witnesses.
Very truly yours,
United States Attorney
by:
Alicon
Assistant United States Attorneys
EFTA00032022


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=== Page 1 ===
To:
From:
Sent:
Mon 8/12/2019 8:02:23 PM
Subject: Epstein, Jeffrey Edward, Reg. No. 73618-054
TEXT.htm
Epstein Psych Observation 7-8-10-2019.pdf
Epstein Psych Observation 7-24-30-2019.pdf
Epstein SW Chronological Log 7-23 & 24-19.pdf
Epstein SW Chronological Log 7-23-19.pdf
FYI.....S/W and Psych Ops docs
Associate Warden
MCC New York
150 Park Row
New York NY 10007
CONFIDENTIAL
SDNY_00009216
EFTA00033745


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=== Page 1 ===
Cc:
To:
From:
Sent:
Sat 7/27/2019 12:13:10 PM
Subject:
Inmate Epstein #76318-054 (Psych Observation)
TEXT.htm
He stated he is feeling dehydrated because he is not drinking enough water since he has Legal visits 12
hours a day.
Thanks,
CONFIDENTIAL
SDNY_00009913
EFTA00034038


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=== Page 1 ===
From:
=
=
To:
=
)"
Subject: Voice Message Attached from 2103718899 - USAA
Date: Mon, 31 Aug 2020 20:05:37 +0000
Attachments: 2103718899_20200831_160537.wav
Time: Aug 31, 2020 4:05:37 PM
Click attachment to listen to Voice Message
EFTA00032212


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: In re Application to Unseal Civil Discovery Materials SDNY 19-mc-00179
Date: Tue, 16 Apr 2019 19:37:15 +0000
Importance: Normal
Attachments: 19-MC-00179_Sealed_Order_4.15.19_Stamped.pdf
From:
Sent: Tuesday, April 16, 2019 14:25
To:
Subject: In re Application to Unseal Civil Discovery Materials SDNY 19-mc-00179
Mr.
Please see the attached PDF for an Order that was filed under seal today in 19-mc-179.
Thank you,
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
EFTA00032516


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=== Page 1 ===
From: New York Law360 <news-alt@law360.com>
To:
Subject: Harvard, NYU Law Reviews Biased Against White Men, Suit Says
Date: Wed, 10 Oct 2018 07:31:30 +0000
Law360 New York
NEW YORK
Wednesday, October 10, 2018
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Hoops Recruit's Dad Tells Jury Cash Wasn't Only Factor
The father of former University of Louisville recruit Brian "Tugs" Bowen told a
Manhattan jury Tuesday that the hoops powerhouse was the right place for
his son regardless of cash payments he received, as lawyers for three men
accused of funneling illegal secret payments from Adidas to the basketball
dad pushed the narrative that they had no criminal intent. Read full article
Harvard, NYU Law Reviews Biased Against White Men: Suit
The law reviews at Harvard Law School and the New York University School
of Law discriminate against white men when selecting their members and
which articles they will publish, according to a pair of suits filed in
Massachusetts and New York federal courts. Read full article
Listen to our new podcast here
Ex-Goldman CEO Aide Accused In Wine Theft Leaps To Death
LAW FIRMS
A former assistant to the CEO of Goldman Sachs who was expected to plead
guilty on Tuesday to stealing $1.2 million in rare wines from his former
Alston & Bird
employer was found dead at a Manhattan hotel that afternoon in an apparent
Arnold & Porter
suicide. Read full article
Belkin Burden
Royal Park Can't Revive $3.7B RMBS Suit, NY Court Rules
Brown Law Firm
Cassin & Cassin
A New York appellate court said Tuesday that a lower court was right to toss
Royal Park Investments SA/NV's $3.7 billion suit accusing four major banks
Clifford Chance
of committing fraud in connection with the sale of residential mortgage-
Cravath Swaine
backed securities, finding the Belgian bank did not have standing to bring
Davis Polk
negligence and fraud claims. Read full article
Donnelly Conroy
2nd Circ. Mulls Unsettled McDonnell Issues In Guinean Case
Dorsey & Whitney
A convicted former Guinean mining minister's attorney told an appeals court
Fried Frank
panel on Tuesday that the Supreme Court's McDonnell ruling should apply to
Greenberg Traurig
foreign bribery law, leading one appellate judge to muse that the Second
Hengeler Mueller
Circuit has yet to limit the ruling to specific laws. Read full article
Jones Day
INSURANCE
Kellogg Hansen
Kennedys CMK
Insurer Must Pay $1.2M In Tainted Milk Row, 2nd Circ. Told
Kent Beatty
Harleysville Worcester Insurance Co. on Tuesday urged the Second Circuit to
Korein Tillery
uphold a ruling that it is entitled to reimbursement from Wesco Insurance Co.
Latham & Watkins
for nearly $1.2 million Harleysville shelled out defending and settling two suits
accusing a trucking company of delivering contaminated milk to a dairy plant,
LeClairRyan
saying that Wesco forfeited its primary arguments. Read full article »
Lee Litigation Group
Loeb & Loeb
SECURITIES & WHITE COLLAR
Manatt Phelps
EFTA00032964

=== Page 2 ===
Ex-Marks Paneth Accountant Charged In $2M IP Scheme
Meister Seelig & Fein
Morgan Lewis
Federal authorities in Florida have arrested the former managing partner of a
Manhattan accounting firm on charges he defrauded investors of $2 million
Moskowitz LLP
through a sham intellectual property company he created. Read full article
Nexsen Pruet
Nijman Franzetti
Shareholder Fires Back At Dismissal Bids In 6D Global Suit
Norton Rose Fulbright
A 6D Global Technologies Inc. shareholder on Friday swatted back at a trio of
Ogletree Deakins
dismissal bids in New York federal court, deriding "feeble attempts" by the
company, its former directors and a private equity firm's CEO to escape
Otterbourg PC
claims that they allowed the digital marketing company's share price to be
Pinsent Masons
manipulated. Read full article
Riker Danzig
Robbins Geller
PRODUCT LIABILITY
Sidley Austin
Starbucks Sued Over White Chocolate Energy Drink Labeling
Spolzino Smith
A New York Starbucks customer is suing the coffee chain in Manhattan
Sullivan & Cromwell
federal court, claiming it has deliberately deceived customers by selling white
Tarter Krinsky
chocolate-flavored energy drinks that do not contain white chocolate. Read
Weil Gotshal
full article
Willkie Farr
INTELLECTUAL PROPERTY
COMPANIES
Instagram Art Show Was Fair Use, Richard Prince Says
Adidas AG
Visual artist Richard Prince is pushing to end copyright litigation over his
Agri-Mark Inc.
Instagram-themed art exhibit, arguing he was allowed to display largely
Altman Weil Inc.
unaltered versions of other artists' images because he used them in "a
Amazon.com Inc.
radically different aesthetic context." Read full article
American Bar Association
MEDIA & ENTERTAINMENT
Ampal-American Israel Corp.
Barilla Holding SpA
Nicki Minaj Didn't Return Rental Clothes, NY Stylist Claims
Barnes & Noble Inc.
A professional stylist accused rap star Nicki Minaj in New York state court on
Bayer AG
Friday of failing to pay for $73,000 worth of clothes and styling services,
Bloomberg
saying he was now facing "serious financial hardship" because she stiffed
him. Read full article
CVC Capital Partners
Chicago Bar Association
EMPLOYMENT
Credit Suisse Group AG
Delek Drilling
Bloomberg Workers Seek $13.8M In Costs, Fees In oT Suit
Deutsche Bank AG
A class of Bloomberg LP help desk representatives have told a New York
Equifax Inc.
federal judge they are entitled to $13.77 million in attorneys' fees and costs in
their suit alleging the company wrongfully excluded them from overtime pay,
First Republic Bank
the same day the parties sought final approval of a settlement in the case.
Fordham University
Read full article
Goldman Sachs Group Inc.
III. Atty Accused Of Defaming EB-5 Fund To Chinese Investors
HSBC Holdings PLC
HighQ Solutions Ltd.
The U.S. Immigration Fund LLC has sued an Illinois attorney, his business
partner and a Hong Kong consulting firm for fraud and defamation in New
Honeywell International Inc.
York state court, alleging they defrauded the EB-5 center out of millions by
Instagram Inc.
making false statements about the center to Chinese investors seeking EB-5
Intel Corp.
visas and inducing them to withdraw their capital from the fund. Read full
International Centre for Settlement
article
of Investment Disputes
BANKRUPTCY
JPMorgan Chase & Co.
Kraft Foods Inc.
FIKA's Proposed $11M Sale To Ch. 11 Lender Approved
LexisNexis Group
FIKA, a bankrupt New York City coffee chain inspired by Swedish coffee
Linkedln Corp.
culture, inched forward Tuesday in its bid to sell the business to its secured
Lone Star Funds
lender in Chapter 11 for roughly $11.4 million and remain in operation. Read
full article
M&T Bank Corp.
EFTA00032965

=== Page 3 ===
Ampal Reaches $150M Deal To Resolve Gas Row With Egypt
Mayo Foundation for Medical
Bankrupt Ampal-American Israel Corp. has reached a $150 million deal to
Education and Research
resolve several arbitrations involving Egypt and two state-owned oil and gas
Microsoft Corporation
companies - one of which resulted in a $1.033 billion arbitral award against
Monsanto Co.
Egypt - stemming from a terminated natural gas deal, according to
documents filed in New York bankruptcy court. Read full article »
Morgan Stanley
National Basketball Association
CORRECTED: Ex-Exec Of Modi Jewelry Co. Seeks Access To
National Collegiate Athletic
D&O Coverage
Association
The ex-president of a company owned by billionaire jeweler Nirav Modi on
New York Post
Thursday asked a New York bankruptcy court for an order allowing one of his
New York Times Co.
company's directors and officers insurance to pay for his legal defense,
New York University
saying the policy proceeds are not estate property. Correction: A previous
version of this story incorrectly identified the individual filing the motion. The
Noble Energy, Inc.
error has been corrected. Read full article
Signature Bank
Square Inc.
BANKING
Starbucks Corporation
NCUA Seeks Sub To Bring RMBS Suit Against Deutsche Bank
The Bank of New York Mellon
Corp.
The National Credit Union Administration has urged a New York federal judge
to allow the substitution of a new plaintiff to pursue claims against Deutsche
U.S. Bancorp
Bank National Trust Co. over a number of residential mortgage-backed
UBS AG
securities trusts, arguing that this swap would address standing issues
United Nations Commission on
highlighted in a similar suit brought by the agency against U.S. Bank. Read
International Trade Law
full article
UnitedLex Corp.
ENERGY & ENVIRONMENTAL
Wells Fargo & Co.
GOVERNMENT AGENCIES
High Court Won't Review NY Honeywell Cleanup Fight
Bureau of Citizenship and
The U.S. Supreme Court on Tuesday declined to resurrect a suit by upstate
Immigration Services
New York residents against Honeywell International Inc. that accused the
company of exposing them to "hazardous concentrations of toxic vapor"
Delaware Court of Chancery
during a cleanup of Onondaga Lake. Read full article
Federal Bureau of Investigation
Federal Election Commission
REAL ESTATE & DEVELOPMENT
Illinois Supreme Court
Internal Revenue Service
NYC Real Estate Week In Review
International Chamber of
More than a dozen law firms landed work on the largest New York City
Commerce
transactions for which deeds were filed last week, with Loeb & Loeb LLP
helping Bank of New York Mellon Corp. land a $352 million purchase of an
National Credit Union
office building one block north of One World Trade Center. Read full article
Administration
Securities and Exchange
Real Estate Rumors: FPA, Pentaurus, Mautner-Glick
Commission
FPA Multifamily has reportedly bought an Illinois apartment complex for $65
U.S. Attorney's Office
million, real estate investment firm Pentaurus is said to have picked up 60
U.S. Department of Justice
Florida town homes for $13 million, and Mautner-Glick has reportedly bought
U.S. Environmental Protection
two New York residential and retail buildings for $19 million. Read full article
Agency
U.S. Supreme Court
EXPERT ANALYSIS
United States Bankruptcy Court for
the Southern District of New York
Defamation In Litigation: A Primer On Privileges In NY
Under New York law, statements made in court and other litigation-related
communications are, in most cases, privileged. But these privileges have
limits, and it behooves litigants - particularly those inclined to speak publicly
about their cases - to be aware of them, says Jonathan Bloom of Weil
Gotshal & Manges LLP. Read full article
Opinion
Trump Family Tax History: A Professional Evaluation
EFTA00032966

=== Page 4 ===
From his perspective as a tax defense attorney for the past 30 years, Steve
Moskowitz of Moskowitz LLP weighs in on the allegations of past tax
impropriety by the Trump family. Read full article
Knowledge Management: An Unsung Hero Of Legal Innovation
As technology evolves, law firms are increasingly looking for ways to improve
communication, transparency and service for their clients. Firms should put
knowledge management at the core of their value proposition to create a
competitive advantage, says Rob MacAdam at HighQ. Read full article »
LEGAL INDUSTRY
Gains Stall For Female Partners In Numbers, Salaries
The number of female equity partners at top law firms has barely budged in
more than a decade, with few signs of women making significant inroads into
the upper tiers of management or earning as much as men, according to a
report from the National Association of Women Lawyers. Read full article
Justice Kavanaugh Not Shy At 1st Supreme Court Arguments
Justice Brett Kavanaugh got off to a quick start at the U.S. Supreme Court
following a rocky confirmation battle over sexual misconduct claims that
divided the nation, asking numerous questions Tuesday at his first pair of oral
arguments just days after he was sworn in as President Donald Trump's
second appointee to the high court. Read full article
When A Justice's Vote Is Pivotal, Politics Rules: Study
A closely divided high court is more likely to hand down decisions that were
determined on ideological grounds and were intended to reshape the law,
rather than relying on legal precedent, new research shows. Read full article
Dorsey & Whitney Names New Managing Partner
Minneapolis-based Dorsey & Whitney LLP on Tuesday named Bill Stoeri, a
trial lawyer who has worked at the law firm for more than 30 years, as its new
managing partner starting next year. Read full article
Feature
Chicago Courts Join Judiciary's Sex Harassment Reckoning
After disciplining a judge for allegedly sexually harassing a prosecutor,
Chicago's court system this month is set to hold its first-ever training on
sexual harassment for all of its nearly 400 judges, part of a growing trend in
state courts as they grapple with #MeToo. Read full article
Adidas Taps Bayer US Legal Head For New General Counsel
The former head of legal for Bayer U.S. has been appointed general counsel
of Adidas AG, the Germany-based sportswear manufacturer said Tuesday.
Read full article
Interview
15 Minutes With Barilla's Americas General Counsel
General counsel of the Americas for Barilla Group, Talita Erickson, recently
spoke to Law360 about what she looks for in outside counsel, what she
thinks about the billable hour, and the recent regulations that have had the
most impact on her business. Read full article
Legal Tech Download: A Lawsuit-Generating Chatbot
The world of legal technology is quickly evolving, with new products coming
to market in rapid succession. Here, Law360 takes a look at five recent
developments. Read full article »
JOBS
Search full listings or advertise your job opening
EFTA00032967

=== Page 5 ===
Associate
L&E Partner -Mid-sized NYC law firm
Mendes & Mount, LLP
Schoen Legal Search
New York, New York
New York City, New York
Employment Associate / NY mid-size law
Professional Development Coordinator -
firm
Attorney Training and Development
Schoen Legal Search
Filcro Legal Staffing
New York, New York
New York, New York
Labor & Employment Associate
Corporate Law - Paralegal Supervisor
Epstein Becker & Green, PC
TOP AM LAw Firm
New York, New York
New York, New York
Billing Coordinator Elite Enterprise Billing
Global Mobility Services Specialist
Systems
Filcro Legal Staffing
National Law Firm
New York, New York
Great Neck, New York
Senior Finance Paralegal - Structured
Corporate Associate (New York Office)
Finance
McCarter & English, LLP
TOP AM LAw Firm
New York, New York
New York, New York
Trademark Legal Assistant
Litigation Associate
Arnold & Porter
Lipsius BenHaim Law LLP
New York, New York
Kew Gardens, New York
Hogan Lovells US LLP - New York Office -
Junior and Mid-Level Associates for
Intellectual Property Associate, Junior
D&O/Financial Lines Coverage & Litigation
Level
Group
Hogan Lovells US LLP
Kennedys CMK LLP
NEW YORK, New York
New York, New York
Tax Manager- Trust & Estates
Grassi & Co.
Jericho, New York
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=== Page 1 ===
From:
)"
To:
)"
)"
,
)"
Subject: RE: Jury instructions letter
Date: Sat, 20 Nov 2021 23:56:31 +0000
Attachments: 2021-11-20_GM_edits_to_limiting_instructions_v3_
)).docx
Thanks so much,
My thoughts and edits attached. This goes to
next, I think.
From:
Sent: Saturday, November 20, 2021 5:35 PM
To:
is
(
)
>;
)
Subject: Jury instructions letter
Hey team,
Jury instructions letter attached. Comments welcome.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
Event: Accepted: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Start Date: 2019-11-07 18:00:00 +0000
End Date: 2019-11-07 18:30:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2019-11-06 18:38:45 +0000
Date Modified: 2019-11-06 18:38:45 +0000
Priority: 5
DTSTAMP: 2019-11-06 18:17:46 +0000
Attendee: Hudgens, Johanna Rae
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=== Page 1 ===
I have verified Martin Weinberg is an attorney in good standing in Massachusetts. He is permitted to visit Jeffrey
Epstein.
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
(USANYS)"
Date: 7/7/19 6:18 PM (GMT-05:00)
To:
Subject: RE: counsel having difficulty meeting with client
(USANYS)" 07/07/2019 18:18
Massachusetts
From:
Sent: Sunday, July 07, 2019 18:18
To:
(USANYS)
Subject: Re: counsel having difficulty meeting with client
Sorry
just seeing this now. Where is he barred?
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
(USANYS)"
<mailto:
Date: 7/7/19 5:36 PM (GMT-05:00)
To:
<mailto:al
<mailto
Subject: RE: counsel having difficulty meeting with client
(USANYS)" 07/07/2019 17:36
With apologies for the weekend email, we have a defendant, Jeffrey Epstein, who was arrested last night and is currently bein
g detained at MCC, and is expected to be presented on an indictment tomorrow. His attorney, Martin Weinberg, has represe
nted him in the past, and represents him in connection with our case and has been in touch with us throughout the weekend.
He went to MCC today to meet with him in advance of the presentment tomorrow, but was just told he is not allowed in beca
use he is from out-of-state.
We're concerned about the defendant not having access to his attorney in advance of the presentment (as we would be for any
defendant) and so I wanted to reach out to you-
is it at all possible to address this issue so Mr. Weinberg can meet with his client this evening? I'm available anytime at
to discuss, if that's helpful, or Mr. Weinberg can also be reached directly at
if that's easier (though if you reach out directly to him if you could please just let me know afterward I'd be grateful).
thanks very much,
CONFIDENTIAL
SDNY_00008744
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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com>
To:
Subject: 2019 Year In Review: The Legal Industry
Date: Thu, 26 Dec 2019 11:33:27 +0000
Law360 Special
Report
Year In Review
Thursday, December 26, 2019
Follow Law360
LAW FIRMS
iStock-1044578200.jpg
Allen & Overy
Austin LLP
Berry Appleman
Briggs & Morgan
Cohen & Grigsby
Davis Polk
Dentons
Drinker Biddle
Epstein Becker Green
Faegre Baker
Fisher Phillips
Gray Plant Mooty
Greenberg Traurig
Hughes Hubbard
Jones Day
Kirkland & Ellis
Latham & Watkins
Lathrop Gage
LeClairRyan
Mayer Brown
McDermott Will
Milbank LLP
Morgan Lewis
O'Melveny & Myers
5 Trends That Rocked The Legal Industry In 2019
Ogletree Deakins
From some law firms' hard-knuckle responses to discrimination lawsuits filed
Outten & Golden
against them to the Big Four's ongoing creep into the legal sector, these were
Pepper Hamilton
some of the moments and trends that shook the industry in 2019.
Sidley Austin
Skadden
Looking Back: Law360's 2019 Legal Lions And Lambs
Taft Stettinius
It was a big year for explosive news in the legal industry. Here, Law360
rounds up the noteworthy legal industry peaks and valleys with one final legal
Troutman Sanders
lions and lambs list.
Ulmer & Berne
Wiggin and Dana
All Talk, Little Action: BigLaw Mergers Were Scarce In 2019
Williams & Connolly
In a record-breaking year for total U.S. law firm combinations, blockbuster
Willkie Farr
merger announcements were few and far between. But experts say a slew of
EFTA00032918

=== Page 2 ===
firms expressed interest and began feeling out a tie-up this past year, which
WilmerHale
could mean merger madness at the top end of the market in 2020.
Zuckerman Spaeder
Poetic Justice: How Judges Got Creative In 2019
COMPANIES
Amid headline-grabbing decisions and groundbreaking precedent out of
Altman Weil Inc.
federal courts in 2019, judges also injected bits of levity and creativity in their
American Bar Association
otherwise serious work, quipping about that last "Game of Thrones" season or
quoting the Bard. Here, Law360 presents some of the best poetry, zingers
BlueStone Natural Resources Il
and pop-culture references that popped up in opinions over the past year.
LLP
Chevron Corp.
The 7 Most Divisive Judicial Confirmations Of 2019
Deloitte Touche
In a banner year for judicial confirmations, senators in 2019 signed off on 20
Ernst & Young LLP
circuit judges and 80 district judges as President Donald Trump clinched his
185th appointment - but in reaching that milestone, Majority Leader Mitch
Google Inc.
McConnell faced a number of heated battles along the way.
Home Box Office Inc.
KPMG International
THE STATE OF THE LEGAL INDUSTRY
Lippman Jungers LLC
The Law360 400
Major Lindsey & Africa
Paypal Holdings Inc.
Kirkland & Ellis LLP has redefined what it means to be the biggest of BigLaw
- weighing in at 2,116 attorneys by year end 2018 and becoming the first firm
PricewaterhouseCoopers
since Law360 began tracking law firm head counts to top 2,000 U.S.-based
International Ltd.
attorneys.
Spectrum Management Holding
Co.
The 2019 Law360 Glass Ceiling Report
Warner Bros.
Our annual survey of the largest U.S. law firms again shines a light on the
lack of parity for female attorneys in private practice. Though women now
GOVERNMENT AGENCIES
make up more than half of law school students, the Glass Ceiling Report
Federal Bureau of Investigation
shows they continue to be underrepresented at all levels of a typical law firm
National Labor Relations Board
and that their numbers dwindle as they move up the ranks.
U.S. Department of Education
The 2019 Law360 Diversity Snapshot
U.S. Department of Justice
U.S. law firms have long touted their commitment to diversity and inclusion.
U.S. Supreme Court
But those goals still seem far from being realized. Law360's annual Diversity
Snapshot indicates only marginal progress on racial and ethnic diversity in the
attorney workforce from year to year, even as demands grow from clients
expecting more diverse legal teams.
PODCAST
Law360's Pro Say: Will The Glass Ceiling Ever Break?
For years women have been looking around their law firms and seeing mostly
men in leadership. When will things change? On the latest episode of
Law360's Pro Say podcast we discuss our annual Glass Ceiling report, which
reveals a glacial pace for increased gender parity in the law, and we talk to
one prominent female attorney who managed to crack the glass ceiling.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Date: Wed, 16 Jun 2021 14:53:25 +0000
Attachments: Ex._C_Sealed.pdf
From:
(USANYS)
Sent: Wednesday, June 16, 2021 10:40 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S?
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:45 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
In the spirit of completeness, I'm also attaching their replies.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:20 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Re: Question re AJN/Maxwell Suppression Hearing
Goodness!
Associate U.S. Attorney
Southern District of New York
On Jun 15, 2021, at 5:06 PM,
(USANYS)
wrote:
She filed 12 (!!) separate MOLs as a way to evade the Court's page limits. Defense attorneys have started doing that
over the last few years.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 4:25 PM
To:
(USANYS)
EFTA00032725

=== Page 2 ===
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Dumb Q: why does Maxwell have two memos of law?
From:
(USANYS)
Sent: Tuesday, June 15, 2021 2:19 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the
McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our
motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial.
Thanks very much.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 10:09 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Sure, set a time other than 2:00. I'm in the office. Or Webex
From:
(USANYS)
Sent: Tuesday, June 15, 2021 9:11 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Question re AJN/Maxwell Suppression Hearing
Hi
We had an issue come up related to the upcoming suppression hearing (no date set yet, although we expect one)
related to
that we'd like your thoughts on. Let us know a convenient time to stop by over the next
few days, thanks.
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE
No. 20 Civ. 484 (JGK) (DCF)
Plaintiff,
V.
DARREN INDYKE, et al.,
Defendants.
DECLARATION OF
, declares under penalty of perjury pursuant to 28 U.S.C. §
1746 as follows:
1.
I submit this declaration in response to a subpoena dated June 10, 2020, from the
plaintiff in this action, directing me to produce documents and appear for a deposition. I
understand this declaration is being submitted in lieu of appearing for a deposition.
2.
Beginning in 1991, I worked as a pilot for Mr. Jeffrey Epstein ("Epstein") and
Epstein-affiliated entities.
3.
Through flying for Mr. Epstein, I met Ms.
I do not recall when or
where specifically I met Ms.
for the first time, or the first flight she was on, but it was
likely in the mid to late 1990s.
4.
I have attached as Exhibit A my flight logs from the time period between January
1, 1994 and December 31, 1997. I made these records at or near the time of the flights reflected
therein, they reflect my knowledge at that time, and it was my practice to regularly make such
records during the 1994-1997 time period. With respect to the names in the "Remarks,
EFTA00031984

=== Page 2 ===
Procedures, Maneuvers, Endorsements" column, my general practice during this time was to use
this column to record the number of passengers on the plane. If I knew the passenger's name or
had learned that name during the course of the trip, my general practice was to record that name.
If I did not know or learn the name, I would write down a generic description, for example,
"Baby," "Nanny," "1 Male," "1 Female."
5.
The first time the name
appears in my flight logs between January 1,
1994 and December 31, 1997 is on November 11, 1996. This entry reflects that a
" no
last name, was on a flight on that date from West Palm Beach, Florida, to Teterboro Airport in
New Jersey.
6.
also appears in an entry on May 9, 1997. This entry reflects that a
" no last name, was on a flight on that date from Teterboro Airport to Santa Fe, New
Mexico.
7.
I have no specific recollection of either of these flights, which occurred over 23
years ago. In addition to Ms.
,
I recall one other individual with the first name
who flew on Mr. Esptein's planes, although my recollection is that this other
did not
begin flying until the early 2000s.
8.
I declare under penalty of perjury that the foregoing is true and correct to the best
of my recollection.
Executed on July
17
2020
,
2
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=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE: August 10, 2019
TO:
, Captain
FROM:
, Clinical Nurse
SUBJECT: Medical Emergency Unit (CA)
On Saturday, Aug 10, 2019, at approximately 0633 a.m., I responded to a medical emergency 9S,
upon arrival Inmate (EPSTEIN, J. Reg #: 76318-054) was received on the floor of his cell
unresponsive with CPR in progress by correctional officers, Inmate was Cold, with circumferential
Bruising around the neck and posterior mottling, Pupils Fixed and dilated, No Palpable pulses
were felt, At this time 0635 a call placed for EMS, CPR Continued, an AED was
Placed with No shock advised, CPR was continued. Inmate was transported to HSU treatment
room with CPR in progress, where a 18g hep lock to L AC was placed and, O2 15 Lt ViA BVM.
Pulse Check NO SHOCK advised. EMS and Paramedics arrived 0656, Placed on cardiac
Monitor shows asystole Resumed CPR, Inmate was intubated by Medics, 3 Rounds of
Epinephrine administered, and Pulse Check asystole, Inmate was transported to Local ER with
CPR in progress at approximately 0710.
CONFIDENTIAL
SDNY_00008861
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Inmate Epstein #76318-054 is being taken off of Psych Observation and needs to be housed with an appropriate cellmate.
Suicide Watch
None
Psych Observation
None
Thank you,
CONFIDENTIAL
SDNY_00009905
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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Cc:
(USANYS)"
)"
Subject: RE: Rule 23 motion
Date: Wed, 22 Jul 2020 22:21:29 +0000
Attachments: 2020-07-22,_GM,_letter_to_Judge_Nathan_re_Local_Rule_23.1_v2.docx
Very sorry for the delay-I've lost count of how many times I've had to restart my computer today. Attached is the draft in
its current form.
From:
(USANYS)
Sent: Wednesday, July 22, 2020 6:18 PM
To:
Cc:
(USANYS)
in
>;
Subject: RE: Rule 23 motion
Okay, thanks. On the draft, if someone could just send me whatever you have at whatever stage it is now, I'll take it from
here as I really want to get this up to the Brass tonight. Thanks
From:
Sent: Wednesday, July 22, 2020 5:59 PM
To:
(USANYS)
Cc:
(USANYS)
in
)
is
Subject: RE: Rule 23 motion
Perfect, and I did - I mentioned we'd be filing a response in the next day or so.
From:
(USANYS)
Sent: Wednesday, July 22, 2020 17:57
To:
Cc:
(USANYS)
is
is
)
Subject: Re: Rule 23 motion
I think no position is right, although I think you can tell him we plan to file something in response soon. Speaking of, what
is the status of the draft?
Sent from my iPhone
On Jul 22, 2020, at 3:58 PM,
wrote:
Just FYI for everyone, Brad just called and asked if we had a view as to whether victims' counsel should file a response to
the defense motion from last night. I said my assumption was that we had no position or view at all with respect to
EFTA00032085

=== Page 2 ===
what victims' counsel should or should not do, and wouldn't direct victim counsel on something like that, but that I
would let him know if that was incorrect. So please let me know if we should convey something else, and I'm happy to
pass it along, otherwise I've conveyed our neutrality.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: Fwd: Ghislaine Maxwell 02879-509
Date: Wed, 16 Jun 2021 14:37:07 +0000
Begin forwarded message:
From: BOBBI C STERNHEIM
Date: June 16, 2021 at 10:23:09 AM EDT
To: Sophia Papapetru
Cc:
)"
, Christian Everdell
Subject: Ghislaine Maxwell 02879-509
Good morning-
As reported yesterday, the modifications made in the VTC room
are negatively impacting attorney-client communication.
The video is blurry; the audio includes distorting noises.
I am requesting that these problems be remedied immediately.
Also, I am bringing to your attention the inappropriate behavior of the
guards presently on Ms. Maxwell's detail: threatening discipline if
Ms. Maxwell is "off camera" while leaning against a wall to soothe her aching
back; barking orders regarding the noise emanating from the washing machine
and the pace of her gait when walking; laughing amongst themselves as if any of this is funny.
The manner in which some of the guards responded to me on Sunday gives me reason to be concerned
about how they treat Ms. Maxwell when out of public view.
The courtesy of a response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
Covid-19 Notice: The
office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
EFTA00032722

=== Page 2 ===
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Cc:
(USANYS)"
)"
)"
Subject: FW: Declaration
Date: Sun, 01 Aug 2021 00:54:24 +0000
Attachments:
Executed
Dec_Active_52049129_1.PDF;
2021.07.30
prep_VTC_notes.pdf
Inline-Images: image001.jpg; image002.jpg
Hi,
Would one of you please save the attached 2 pdfs in the testifying witness 3500 and witness folders for
on
the Epstein share?
Thanks,
From: Quigley, Brendan
Sent: Friday, July 30, 2021 12:22 PM
To:
)
Subject: Declaration
Brendan F. Quigley [bio]
Partner
Baker Botts L.L.P.
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address above
and destroy any and all copies of this message.
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: FW: Letter re: Briefing Schedule
Date: Fri, 04 Dec 2020 16:57:40 +0000
Attachments: 2020.12.04_Letter_to_Judge_Nathan_re_Briefing_Schedule.DOCX
Inline-Images: image005.jpg; image006.jpg
Fine with me. Any issues on your end?
From: Christian Everdell
Sent: Friday, December 4, 2020 11:44 AM
To:
)
>;
is
(USANYS)
Cc: Mark S. Cohen
>; 'BOBBI c STERNHEIM'
Subject: Letter re: Briefing Schedule
and
-
Attached is a draft of the letter to Judge Nathan regarding the briefing schedule. Unless you have any comments, we will
send it to the judge in the next hour or so.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
To:
From:
Sent:
Sun 8/11/2019 10:15:29 AM
Subject: Lieutenant's log and daily activity log for Saturday, August 10, 2019.
TEXT.htm
Daily Activities Report 8-10-2019.docx
LIEUTENANT'S LOG 08-10-2019.docm
Lieutenant's log and daily activity log for Saturday, August 10, 2019.
Lieutenant
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, N.Y. 10007
CONFIDENTIAL
SDNY_00008862
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=== Page 1 ===
From:
To:
(OPR)
Cc:
(OPR)"
Subject: RE: RE: SDNY investigation
Date: Tue, 19 Feb 2019 17:12:37 +0000
Importance: Normal
That works, thanks, and that is the best number for me. So you have it generally, my cell is
and feel free to
call that if there's ever a time-sensitive issue, but l'll be at my desk tomorrow morning.
thanks again,
From
(OPR)
Sent: Tuesday, February 19, 2019 12:10
To:
Cc:
(OPR)
Subject: RE: RE: SDNY investigation
9:30 tomorrow morning? We'll call you then at
unless you provide another #.
Many thanks.
From:
Sent: Tuesday, February 19, 2019 11:59 AM
To
(OPR)
Cc
OPR)
Subject: RE: RE: SDNY investigation
Unfortunately I'm in the grand jury and meetings most of the afternoon, but I'll be free (and in the office) anytime this
evening starting at 5:00, or could talk anytime tomorrow before 2:00. What works best for you?
thanks,
Assistant U.S. Attorney
Southern District of New York
From:
(OPR)
Sent: Tuesday, February 19, 2019 11:35
To:
Cc:
OPR)
Subject: RE: RE: SDNY investigation
EFTA00032511

=== Page 2 ===
- My cocounsel Steve Fenn and I would like to speak with you today, if possible. Is there a good time for us to phone
you?
Regards,
From:
Sent: Tuesday, February 12, 2019 5:28 PM
To:
(OPR)
(OPR)
Subject: RE: SDNY investigation
and
I am one of the AUSAs working on the current investigation of Jeffrey Epstein in the Southern District of New York, and I
was given your contact information by
nd so wanted to be in touch for any deconfliction or discussion that
might be useful with respect to our respective matters. Is there a good time to be in touch sometime this week? I should
generally be able to make myself available at your convenience, and please let me know if any information would be
helpful in advance.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00032512


c1: EFTA00032498
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032498.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To: "Adams,
1"
3"
,
,
)"
Subject: Meet re Epstein forfeiture
Date: Wed, 04 Dec 2019 19:04:06 +0000
Importance: Normal
Attachments: unnamed
EFTA00032498


c1: EFTA00032028
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032028.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Epstein search warrant documents
Date: Thu, 02 Jul 2020 23:19:03 +0000
We haven't but definitely will, thanks.
Sent from my iPhone
On Jul 2, 2020, at 19:15,
(USANYS)
wrote:
Have you run this budget/project by Ed yet? If not, would you mind doing so tomorrow or when you next can. Please
copy me and make clear it is on Epstein/Maxwell. Thanks.
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
)
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a month
later than their estimate from April on when we would get the New York materials, they're also past their estimate of
getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI
materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York
devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point
we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly
format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very effective and
efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a
month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
i
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
EFTA00032028

=== Page 2 ===
From:
)
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
in
)
Cc:
(USANYS)
>;
(NY) (FBI)
>;
)
y.
is
(NY) (FBI)
^
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be
able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
EFTA00032029

=== Page 3 ===
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
-
Cc:
(USANYS)
is
(NY) (FBI)
i
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials? I
think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1
item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council has
provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you
know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
EFTA00032030

=== Page 4 ===
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
-
Cc:
(USANYS)
>;
(NY) (FBI)
V.
>;
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
i
-
is
)
is
(NY) (FBI)
is
(USANYS)
in
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
EFTA00032031

=== Page 5 ===
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see
what the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
>;
Cc:
(NY) (FBI)
i
-
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
)
Cc:
(NY) (FBI)
is
-
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
EFTA00032032

=== Page 6 ===
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
-
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate the
following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
EFTA00032033

=== Page 7 ===
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could
to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I
put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If
there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't
have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to
beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
)
>;
(NY) (FBI)
i
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00032034

=== Page 8 ===
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any
FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which
both we and the agents can access. We're required to have the files in a format that we can produce them to defense
counsel. I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that
the best way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process
-by which I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to
do with the taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original formats,
which I understand will be segregated and designated by device. That should work for us! I was just trying to
understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what
was already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So
now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
EFTA00032035

=== Page 9 ===
FBI NY CART Coordinator
Senior Examiner
From:
)
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago,
but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume
that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
-
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
in
)
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
EFTA00032036

=== Page 10 ===
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it
on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and
send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
)
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
>;
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review
the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
EFTA00032037

=== Page 11 ===
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems
to do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the current
timeline - and also the current timeline on producing the results from those August and September searches? I think
you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months
from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
EFTA00032038

=== Page 12 ===
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
>;
>;
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
i
(USANYS)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
>;
V.
>;
in
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
(NY) (FBI)
>;
>;
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
EFTA00032039

=== Page 13 ===
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but
are you at all able to assist while working remotely? This has been pending for almost two months and we still don't
have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is
the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to
get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a
million documents without much rhyme or reason.
EFTA00032040

=== Page 14 ===
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the
SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points
of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3
drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All
the loose media from the NY apartment is included. All the Windows machines from the NY apartment are included.
Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
(NY)
EFTA00032041

=== Page 15 ===
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues- we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the
two search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed
and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached
is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think
FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to
be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
)
is
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
EFTA00032042

=== Page 16 ===
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated
we delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only
local work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still
working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
which devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
)
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
EFTA00032043

=== Page 17 ===
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously received?
That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder
or file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition
to what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00032044


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c3: VOL00008
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=== Page 1 ===
From: Google Alerts <googlealerts-noreply@google.com>
To:
Subject: Google Alert - "Michael Cohen"
Date: Mon, 08 Jul 2019 22:03:19 +0000
"Michael Cohen"
Daily update July 8, 2019
NEWS
Fed grand jury investigating former Trump inaugural vice chair: Sources
WTVD-TV
A New York-based federal grand jury is investigating whether Elliott Broidy, a wealthy Republican fundraiser
and former co-chair of finance at the
Trump Pal Elliott Broidy Is Facing Yet Another Federal Investigation - Vanity Fair
Prosecutors are investigating whether GOP donor Elliott Broidy used Trump ties to profit - Vox
GOP hush money man Elliott Broidy probed for peddling access to Trump inauguration - New York Daily
News
Full Coverage
FT
Flag as irrelevant
What We Talk About When We Talk About Receipts
Vanity Fair
Trump adviser Omarosa Manigault Newman teased an appearance on the show, saying, "I'm talking
Michael Cohen, and I brought some receipts.
FT
Flag as irrelevant
LETTER TO THE EDITOR: Letters about Trump and Gaetz
Houma Courier
I have read with interest several letters about our local congressman, Matt Gaetz, and his texted threat to
Michael Cohen the night before testimony
FT
Flag as irrelevant
Nancy Pelosi Keeps Coming for the Fab Freshmen of Congress But She Doesn't
Have the Range
The Root
Rep. Alexandria Ocasio-Cortez (D-N.Y.), Rep. Ayanna Pressley (D-Mass.) and Rep. Rashida Tlaib (D-Mich.)
listen as Michael Cohen, former attorney
FT
Flag as irrelevant
EFTA00032589

=== Page 2 ===
Donald Trump's origin story suffers another severe blow
Washington Post
Around the same time that was revealed, former Trump attorney Michael Cohen, who flipped on Trump and
pleaded guilty to several crimes, released
FT
Flag as irrelevant
Jeffrey Epstein charged with two sex trafficking counts - - live
The Guardian
Last year it was revealed that Michael Cohen, Donald Trump's lawyer at the time, arranged for a $1.6m
payment to a Playboy playmate in 2017 to ...
Trump's labor secretary Alex Acosta at center of Epstein scandal after agreeing to sweetheart deal - Daily
Mail
Full Coverage
FT
Flag as irrelevant
A Summary of the Mueller Report Part 3: Russian Contacts with the Trump
Campaign
Fullerton Observer (press release) (blog)
From 2015-2016, Michael Cohen spearheaded the project "including by reporting on the project's status to
candidate Trump and other executives in
FT
Flag as irrelevant
With new law, Trump's state tax returns could go to Congress
cbs4local.com
Specifically, he argued that President Trump considering pardons or favorable treatment for his former
associates Paul Manafort and Michael Cohen,
FT
Flag as irrelevant
A Very Happy Fourth of July: Englewood Gathers for Fireworks
Pascack Press & Northern Valley Press
including state Assemblyman Gordon Johnson, Councilman Charles Cobb, Councilman Michael Cohen
and Police Chief Lawrence Suffern, who
FT
Flag as irrelevant
Adam Schiff renews focus on former Trump business associate Felix Sater
Washington Times
Along with Mr. Trump's former personal lawyer, Michael Cohen, Mr. Sater was supposed to be one of the
people who could shed light on the leverage
FT
Flag as irrelevant
See more results
Edit this alert
You have received this email because you have subscribed to Google Alerts.
Unsubscribe I View all your alerts
RSS
Receive this alert as RSS feed
EFTA00032590

=== Page 3 ===
Send Feedback
EFTA00032591


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
To:
From:
Sent:
Fri 8/16/2019 8:43:39 AM
Subject: Daily Activities Report/Lieutenants Log...8-15-2019
Daily Activities Report 8-15-2019.docx
LIEUTENANT'S LOG 08-15-2019.docm
CONFIDENTIAL
SDNY_00008901
EFTA00033621


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c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032400.pdf
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c0:
=== Page 1 ===
From: Appellate Law360 <news-alt@law360.com
To:
Subject: Up Next At High Court: Census Brawl Dominates Busy Week
Date: Mon, 22 Apr 2019 07:18:20 +0000
Law360 Appellate
APPELLATE
Monday, April 22, 2019
Follow Appellate Law360
TOP NEWS
Law360 Pro Say Podcast
Up Next At High Court: Census Brawl Dominates Busy Week
The Trump administration's attempt to put a citizenship question on the
census is the most high-profile case at the Supreme Court this week, but the
justices will also tackle issues affecting government contractors and Title VII
plaintiffs as it closes out the final argument session of the 2018 term.
Read full article
Analysis
Census Citizenship Question Case Likely To Turn On APA L
Attorneys anticipate that the question of whether Commerce Secretary Wilbur
Ross violated the Administrative Procedure Act will take center stage during
oral arguments at the U.S. Supreme Court on Tuesday, in a case challenging
Listen to our new podcast here
his decision to include a question about citizenship status on the 2020
census.
LAW FIRMS
Read full article
1-800-Law-Firm
Analysis
Akerman
Supreme Court To Mull Title VII's Presuit Hurdles
Alston & Bird
The U.S. Supreme Court on Monday will hear a Texas county's challenge to
Amin Turocy
a Fifth Circuit decision letting a worker pursue a religious discrimination claim
Arnold & Porter
she didn't make to the U.S. Equal Employment Opportunity Commission first,
a case that could resolve a circuit split over what workers have to do before
Baker Botts
bringing federal discrimination suits.
Baker Donelson
Read full article
Baker McKenzie
BakerHostetler
Analysis
High Court FOIA Case May Alter Labor Agency's Disclosures
Ballard Spahr
L
Beveridge & Diamond
The U.S. Supreme Court will hear arguments Monday about the standard for
Blank Rome
invoking a key exception to the Freedom of Information Act in a case that
Burns & Levinson
could make it harder for employers with federal contracts to keep the reams
Carlton Fields
of data they send to the Office of Federal Contract Compliance Programs
under wraps, experts say.
Cleary Gottlieb
Read full article
Clyde & Co
Cohen Milstein
Analysis
Cole Scott
6th Circ. Ruling Raises Bar For Social Media Terrorism Suits
The Sixth Circuit's recent dismissal of a suit blaming Facebook, Twitter and
Consovoy McCarthy
YouTube for radicalizing the man who carried out the 2016 mass shooting at
Cooley
the Pulse nightclub in Florida makes clear that such Anti-Terrorism Act suits
DLA Piper
have a slim chance of success.
Davis Malm
Read full article
Davis Wright Tremaine
EFTA00032400

=== Page 2 ===
DC CIRCUIT
Dechert
Divine & Estes
UPS Can't Reverse Pa. Facility's Unionization, DC Circ. Says
Dressman Benzinger
The D.C. Circuit on Friday rejected UPS Ground Freight Inc.'s effort to
Duane Morris
overturn the unionization of employees at a Pennsylvania distribution facility,
ruling that the International Brotherhood of Teamsters and the National Labor
Earthjustice
Relations Board had followed all the rules for certifying the union.
Edelson PC
Decision attached Read full article
Epstein Becker Green
Evans & Dixon
DC Circ. Won't Nix OK Of $500M Award Against Kazakhstan
Faegre Baker
Kazakhstan was unable to convince the D.C. Circuit on Friday that a lower
Fenwick & West
court had wrongly refused to consider evidence that a half-billion-dollar
Fisch Sigler
arbitration award against it, which was issued to two Moldovan oil and gas
investors, had been tainted by fraud.
Fisher Phillips
1 document attached Read full article
Fletcher Heald
Freeborn & Peters
Wireless Cos. Urge DC Circ. To Toss FCC's Verizon Fee Ruling
Freshfields Bruckhaus
Two wireless providers jointly urged the D.C. Circuit on Friday to reverse a
Fried Frank
Federal Communications Commission ruling that the roaming rates Verizon
Frost Brown Todd
charged to local carriers are reasonable, contending the rates aim to quash
Gibson Dunn
smaller competitors.
Goodwin
1 document attached Read full article
Grant & Eisenhofer
FEDERAL CIRCUIT
Greenberg Traurig
Hart McLaughlin
Fed. Circ. Says Court Wrongly Tossed $7.5M IP Verdict
Hirschfeld Kraemer
A Federal Circuit panel on Friday said a lower court wrongly threw out a $7.5
Hogan Lovells
million jury verdict against Novozymes A/S in a patent case over technology
Holland & Knight
that helps with ethanol processing, deciding the district court erred when it
found the patents were anticipated by an earlier invention.
Horn Aylward
Opinion attached Read full article
Hunter Smith
Hunton Andrews Kurth
Fed. Circ. Backs ITC In Roomba Co.'s Claim Construction Row
Jackson Murdo
A split Federal Circuit panel on Friday sided with the U.S. International Trade
Jones Day
Commission's finding that one of Roomba maker iRobot's patents had not
Keefer Wood
been infringed, delivering a setback to the robot vacuum company months
King & Spalding
after it clinched an import ban against several of its rivals for ripping off
Kirkland & Ellis
another of its cleaning patents.
Opinion attached Read full article
Kobre & Kim
Kutak Rock
Full Fed. Circ. Won't Eye Reviving $19M Samsung IP Verdict
Latham & Watkins
The Federal Circuit won't reconsider its decision to throw out a $19.2 million
Law Offices of Stephan C. Volker
patent infringement verdict against Samsung, despite arguments from a
Leonard Carder
nonpracticing entity that the panel wrongly substituted its own judgment for
Lewis Brisbois
the jury's.
Littler Mendelson
Order attached Read full article
Logan Logan & Watson
Fed. Circ. Affirms PTAB Ax Of Hologic Medical Device Patent
Lucas Magazine
The Federal Circuit on Friday ruled a Hologic patent related to a treatment for
Manatt Phelps
abnormal menstrual bleeding was invalid because it would have been
Markowitz & Richman
obvious, upholding a decision from the Patent Trial and Appeal Board.
Mayer Brown
Opinion attached Read full article
Morgan Brown & Joy
Morgan Lewis
Fed. Circ. Affirms ITC Ax Of Car Toll Patent Claims
Morrison & Foerster
The Federal Circuit on Friday invalidated parts of two patents covering
technology used in electronic toll systems, upholding the U.S. International
Munger Tolles
Trade Commission's decision in an infringement case Neology Inc. brought
Nabors Giblin
against rival companies.
Norris & Keplinger
EFTA00032401

=== Page 3 ===
Opinion attached Read full article
Norton Rose Fulbright
Fed. Circ. Won't Revive Server Patent Axed By PTAB
Oliver Price & Rhodes
The Federal Circuit on Friday upheld the Patent Trial and Appeal Board's
Orrick Herrington
decision to invalidate claims from a Rosetta-Wireless Corp. network server
Panza Maurer & Maynard
patent challenged by Apple and Samsung, and agreed that the data solutions
Paul Hastings
company can't amend its patent.
Paul Weiss
Opinion attached Read full article
Pepper Hamilton
SECOND CIRCUIT
Perkins Coie
Petti & Briones
2nd Circ. Kills $5M Deal Award Against Brazilian Reinsurer
Pierce Bainbridge
The Second Circuit has declined to enforce a $5 million settlement award
Priddy Cutler
against reinsurer IRB Brasil Resseguros SA, finding that it was not a party to
Quinn Emanuel
the agreement between insurer National Indemnity Co. and steelmaker
Companhia Siderurgica Nacional.
Rathbun Cservenyak
1 document attached Read full article
Robbins Russell
Ropes & Gray
2nd Circ. Won't Revive Ex-Mt. Sinai Worker's Race Bias Suit
Sheppard Mullin
The Second Circuit on Friday refused to revive a fired worker's race bias suit
Shook Hardy
against Mount Sinai Health System, saying she'd made a "glaringly
Sidley Austin
disproportionate" number of errors while on the job.
Simpson Logback
1 document attached Read full article
Sive Paget
Skadden
Madoff Trustee Fights Bid To Pause Foreign Clawback Ruling
Smith Law Services
The trustee for Bernie Madoff's fraudulent investment firm has asked the
Second Circuit not to stay its decision that he can claw back billions in Ponzi
Tran Law Firm
scheme proceeds transferred between foreign parties, saying defendants'
Tucker Law Group
planned U.S. Supreme Court appeal is unlikely to succeed.
Venable LLP
1 document attached Read full article
Vorys Sater
Weil Gotshal
THIRD CIRCUIT
White & Case
3rd Circ. Says Immigration Board's Examination Fell Short
Wilk Auslander
The Third Circuit Friday revived a bid from an Indonesian national to avoid
WilmerHale
deportation, finding that the Board of Immigration Appeals failed to mention
Wilson Sonsini
many pieces of compelling evidence he presented and that some of those it
Windels Marx
did mention contradicted its findings.
Wolf Haldenstein
Opinion attached Read full article
Wollmuth Maher
Comcast Keeps Installer Antitrust Suit Win At 3rd Circ.
Wright Close
Wyatt Tarrant
The Third Circuit affirmed a defeat for two Pennsylvania cable installers that
accused Comcast of anti-competitive tactics that drove them out of business,
Young Conaway
reasoning Friday that the telecommunications giant wasn't their only potential
Zebersky Payne
business in the region.
Opinion attached Read full article
COMPANIES
Amazon.com Inc.
NJ Urges 3rd Circ. To Stop PennEast Pipeline Condemnations
American Bar Association
New Jersey on Thursday urged the Third Circuit to overturn a lower court's
American Civil Liberties Union
decision allowing the PennEast Pipeline Co. to file condemnation lawsuits
American Museum of Natural
against the state for land the company wants for a $1 billion natural gas
History
pipeline project.
Apple Inc.
Brief attached Read full article
Association of Corporate Counsel
FOURTH CIRCUIT
BB&T Corp.
BNP Paribas
4th Circ. Trims Sanctions In Fired CarMax Worker's Arbitration
CVC Capital Partners
CalAtlantic Group Inc.
EFTA00032402

=== Page 4 ===
A former CarMax employee who claims he was unfairly fired deserved some
California Rural Legal Assistance
sanctions from a district court for arguing aspects of his arbitration award
Foundation Inc.
appeal that were already rejected, but he also raised a fresh argument that
CarMax Business Services LLC
didn't warrant a penalty, the Fourth Circuit ruled.
Citigroup Inc.
Opinion attached Read full article
Comcast Corp.
FIFTH CIRCUIT
Companhia Siderurgica Nacional
Anti-Straight Bias Not Forbidden By Title VII: 5th Circ.
Edgeworth Economics LLC
A Fifth Circuit panel said Friday that federal workplace discrimination law
Electronic Frontier Foundation
does not block employers from firing straight workers because of their
Essendant Inc.
sexuality, refusing to budge from its stance that Title VII of the Civil Rights Act
Exxon Mobil Corp.
does not cover sexual orientation.
Facebook
Decision attached Read full article
Florida Power & Light Co.
Food Marketing Institute
5th Circ. Says Interstate Travel Axes Oil Workers' oT Suit
GVC Holdings PLC
The Fifth Circuit has affirmed a federal judge's decision absolving Welltec
Inc. from oil field workers' wage and hour claims, saying federal overtime pay
Geico
requirements don't apply because the workers regularly drove across state
General Re Corp.
lines.
Google Inc.
Opinion attached Read full article
HSBC Holdings PLC
Hologic Inc.
Old Ruling Shouldn't Direct Texas Tribal Gaming, 5th Circ. Told
Intel Corp.
The Ysleta del Sur Pueblo argued Thursday that the Fifth Circuit shouldn't
International Brotherhood of
have relied on an error-filled 1994 ruling against it to decide that
Teamsters
the Alabama-Coushatta Tribe of Texas can't offer bingo under state law,
joining the chorus of voices urging the full court to take another look.
International Speedway
3 documents attached Read full article
Corporation
JAMS Inc.
SIXTH CIRCUIT
JEA
Johnson & Johnson
NCAA Referee Passes Death Threats Suit To 6th Circ.
Kapsch TrafficCom AG
An NCAA men's basketball referee on Friday turned to the Sixth Circuit after
Kentucky Bar Association
his suit accusing two Kentucky radio hosts of inciting death threats and
Lowe's Companies Inc.
negative reviews of his business was dismissed under First Amendment
protections.
MGM Resorts International
1 document attached
Read full article
MetLife Inc.
Minerva Surgical Inc.
SEVENTH CIRCUIT
National Collegiate Athletic
Association
$2.8M Housing Fund Row Belongs In New Suit, 7th Circ. Says
National Congress of American
The Seventh Circuit said an Illinois city and a housing company must start
Indians
from scratch in a fight over $2.8 million in reserve funds held by the U.S.
National Hispanic Medical
Department of Housing and Urban Development.
Association
Complaint attached Read full article
National Indemnity Co.
Natural Resources Defense
Uphold Arbitration Order In Biometric Case, Southwest Urges
Council
Southwest Airlines employees who are accusing the company of unlawfully
NeoPollard Interactive LLC
collecting their biometric data are trying and failing to sidestep the federal
New York Immigration Coalition
arbitration requirements preempting their suit, the airline told the Seventh
Circuit on Thursday.
New York University
1 document attached Read full article
Novozymes
Orlando Utilities Commission
NINTH CIRCUIT
PricewaterhouseCoopers
Purdue Pharma LP
Enviros Say Trump Must Live With Keystone Rejection
QUALCOMM Inc.
Two environmental groups have told the Ninth Circuit that the federal
Samsung Electronics Co. Ltd.
government is wrongly attempting to dodge a ruling invalidating its permit for
Southwest Airlines Co.
EFTA00032403

=== Page 5 ===
the Keystone XL pipeline just because President Donald Trump signed a new
Staples Inc.
permit last month.
State Farm
1 document attached Read full article
Taylor Bean & Whitaker Mortgage
Wells Fargo Battles Cert. In Reimbursement Fight At 9th Circ.
Corp.
Wells Fargo urged the Ninth Circuit on Friday to reverse a lower court's
The Nature Conservancy
decision to certify a class of 2,000 home mortgage consultants and bankers
The Walt Disney Co.
who claim the bank didn't reimburse their expenses or pay commissions on
time, arguing that the expenses were optional and commissions can't be
TransCanada Corporation
determined classwide.
Twitter Inc.
Read full article
Uber Technologies Inc.
UniCredit
9th Circ. Gives EPA 90 Days To Respond In Pesticide Case
United Farm Workers
The Ninth Circuit on Friday gave the U.S. Environmental Protection Agency
United Parcel Service Inc.
90 days to respond to objections filed by health and environmental groups
over the agency's decision not to ban the pesticide chlorpyrifos.
United Technologies Corp.
Order attached Read full article
Verizon Communications Inc.
Wal-Mart Stores Inc.
ELEVENTH CIRCUIT
Wells Fargo & Co.
Yale University
11th Circ. Tosses Underpayment Class Action Against Geico
Yelp Inc.
The Eleventh Circuit on Friday threw out a class action accusing Geico of
YouTube Inc.
under-reimbursing health care providers for their services, holding that the
iRobot Corporation
lead plaintiff lacked standing to bring the suit in the first place.
Opinion attached Read full article
GOVERNMENT AGENCIES
Alabama-Coushatta Tribe of Texas
NEW YORK
Chicago Department of Aviation
NY Panel Greenlights Museum Of Natural History Expansion
Delaware Court of Chancery
A New York state appeals court on Thursday greenlighted the American
Department of Commerce
Museum of Natural History's planned expansion into Theodore Roosevelt
Equal Employment Opportunity
Park, finding that the museum has had a right to the disputed land since
Commission
1877.
European Commission
Opinion attached Read full article
European Union
Federal Bureau of Investigation
FLORIDA
Federal Communications
Commission
Home Builder Gets Atty Fees In Property Maintenance Suit
Federal Energy Regulatory
Home builder CalAtlantic can recover attorney fees after residents at a
Commission
Florida development dropped a lawsuit against it over property maintenance,
Federal Trade Commission
with a state appeals court finding Friday that the suit fell within fees
provisions in a declaration governing the community.
Florida State Senate
Opinion attached Read full article
Florida Supreme Court
International Trade Commission
Fla. Energy Choice Ballot Initiative Attacked From All Corners
Montana Department of Revenue
A slew of major Florida interests that are rarely in harmony have lambasted a
National Indian Gaming
ballot initiative that purports to create a right to a competitive energy market
Commission
but that opponents say will upend the energy market in the Sunshine State
National Labor Relations Board
8 documents attached Read full article
Native Village of Noatak
New Jersey Department of
Carlton Fields Nabs Fla. Appellate Pro From Akerman
Environmental Protection
Carlton Fields has brought aboard a Florida appellate and trial litigator and
Office of Federal Contract
former St. Petersburg Times journalist as of counsel in its Miami and Tampa
Compliance Programs
offices, the firm announced Thursday.
Securities and Exchange
Read full article
Commission
KANSAS
Texas Workforce Commission
U.S. Census Bureau
U.S. Department of Agriculture
EFTA00032404

=== Page 6 ===
Med Mal Suit Filed 1 Day Late Nixed By Kan. Supreme Court
U.S. Department of Homeland
The Kansas Supreme Court on Friday affirmed the dismissal of a suit
Security
accusing health care providers of negligently causing a patient's death,
U.S. Department of Housing and
saying the patient's estate failed to present evidence that an electronic filing
Urban Development
issue caused the suit to be lodged one day after the statute of limitations
U.S. Department of Justice
expired.
U.S. Department of Labor
Opinion attached Read full article
U.S. Department of State
KENTUCKY
U.S. Department of Transportation
U.S. Environmental Protection
Ky. Court Upholds Atty Firing For Refusing Non-Solicit Deal
Agency
Kentucky's highest court has unanimously affirmed a lower court's ruling that
U.S. House of Representatives
a law firm did not wrongfully terminate an attorney after she refused to sign a
U.S. Immigration and Customs
non-solicitation agreement involving clients, as the deal did not violate state
Enforcement
legal ethics rules.
U.S. Supreme Court
Opinion attached
Read
full
article
United States Court of Appeals for
the Third Circuit
MICHIGAN
Wisconsin Supreme Court
Ysleta del Sur Pueblo
Live Nation Not Responsible For Concertgoer's Broken Ankle
Promoter Live Nation and Michigan International Speedway are off the hook
from a lawsuit brought by a concertgoer who fell and broke her ankle in
nearby woods while leaving a music festival, a Michigan appeals court held
Thursday.
2 documents attached Read full article
MONTANA
Exxon Tells Mont. Justices Dividend Deduction Cap Improper
The Montana Department of Revenue ignored its own guidance when the
agency didn't permit Exxon Mobil Corp. to fully deduct dividend payments
from subsidiaries that hold most of their business assets internationally, the
oil giant told the state Supreme Court.
Brief attached Read full article
EXPERT ANALYSIS
In Virtual Teams For Mass Torts, The 'Law Team' Is Critical
A critical component of any virtual law team assembled for mass tort litigation
is a dedicated "law team," which tackles the legal strategy and drafts the
many necessary pleadings, motions and other submissions, say attorneys at
Pepper Hamilton and Faegre.
Read full article
LEGAL INDUSTRY
Analysis
BigLaw Forced Arbitration Expected To Survive Amid #MeToc
Even though social media pressure spurred on by Harvard law students has
led several BigLaw firms to change course on mandatory arbitration, experts
say arbitration has gotten a bad rap and so-called coercive contracts, in
some form, will ultimately survive the #MeToo movement.
Read full article
Analysis
Looking To Go Green? Here's How It Can Work For Your Firm
As another Earth Day arrives, environmental consciousness is on the minds
of many in the legal industry, and despite a number of challenges, going
EFTA00032405

=== Page 7 ===
green is not only a possibility but an opportunity as well.
Read full article
In Civil Rights Arena, Practice Groups A Rare But Potent Force
Although a rarity among firms, dedicated practice groups focused on civil
rights cases can have a big impact, proponents say, taking cases solo
attorneys and government regulators can't.
Read full article
Analysis
5 Times Lawyers Settled During The Big Show
Apple and Qualcomm grabbed headlines when they decided to settle their
differences before a San Diego federal jury could decide their multibillion-
dollar antitrust dispute. But they aren't the first high-profile litigants to think
twice about having a jury decide their fate once they got to court.
Read full article
Analysis
Gibson Dunn Ups The Ante On Gambling After High Court Win
Gibson Dunn, the law firm that led the fight to overturn a federal ban on
sports betting, has launched a revamped practice group focused on sports
betting and gambling, positioning itself to take advantage of the rapidly
expanding, newly legal market.
Read full article
Baker Donelson's Growth Recognized Its Roots, Ex-Chief Says
During Ben Adams' 16 years at the helm of Baker Donelson, the firm doubled
its offices and attorneys, carrying out a growth strategy that the departing
chairman told Law360 bet on the firm's roots to prepare for its future.
Read full article
Q&A
Q&A With 'Queen Of Torts' Sheila Birnbaum
Dechert LLP's Sheila Birnbaum, known as the "Queen of Torts," recently
discussed with Law360 the changes in product liability laws she has seen
over her long career, her proudest achievement as a lawyer and the
challenges of representing Purdue Pharma in the multidistrict litigation over
the opioid crisis.
Read full article
More Women Taking Reins Among Tech Giants' Legal Chiefs
Women are increasingly heading up the legal departments of the largest
companies in California's Silicon Valley as well as the corporations on the
S&P 100, though men continue to hold the bulk of those positions, a biannual
report by Fenwick & West LLP reveals.
Read full article
Most 2016 Law Grads Who Took The Bar Passed, ABA Says
About 88.6% of 2016 law school graduates who took the bar exam within two
years of completing school passed the test, the American Bar Association
said Friday, noting that the class of 2016's two-year success rate is about the
same as that of 2015 graduates.
Read full article
GC Cheat Sheet: The Hottest Corporate News Of The Week
Google has been accused in a derivative suit of hiding workplace
harassment, a Duane Morris partner said law firms are dropping the ball in
addressing misconduct and employers are seeking to fortify Trump
administration regulations against court attacks. These are some of the
stories in legal news you may have missed in the past week.
Read full article
EFTA00032406

=== Page 8 ===
In Case You Missed It: Hottest Firms And Stories On Law360
For those who missed out, here's a look back at the law firms, stories and
expert analyses that generated the most buzz on Law360 last week.
Read full article
Podcast
Law360's Pro Say: Mueller Madness
After more than two years of speculation, Special Counsel Robert Mueller's
report about Russian interference with the 2016 election has been released
and there are plenty of legal revelations to unpack. So we'll do just that on
this week's Pro Say podcast.
Read full article
JOBS
Search full listings or advertise your job opening
Patent Attorney/Patent Agent
Personal Injury & Property Damage
Troutman Sanders LLP
Associate
New York, New York
Hinshaw and Culbertson
Ft Lauderdale, Florida
Real Estate Associate
Labor & Employment Associate - (1+ yrs
Duane Morris
Exp.)
Philadelphia, Pennsylvania
Jones Day
San Diego, California
Senior Litigation Associate
Business Associate Attorney . Junior to
Duane Morris
Mid-Level
Cherry Hill, New Jersey
Perkins Coie LLP
Portland, Oregon
Intellectual Property Docket Clerk
Patent Litigation Associate Attorney -
Carter, DeLuca, & Farrell, LLP
Junior
Melville, New York
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Phoenix, Arizona
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Chemistry Patent Attorney/Agent
Carlson, Calladine & Peterson LLP
Klarquist Sparkman, LLP
San Francisco, California
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Patent Attorney
Junior Associate (1-3 Years) Intellectual
Dority & Manning, P.A.
Property - Engineering
Greenville, South Carolina
Leydig, Voit & Mayer
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Area, D.C.), -
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Hartford, Connecticut
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Biotech Patent Agent or Attorney
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Dallas, Texas
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Richmond, Virginia
NYC, New York
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EFTA00032407

=== Page 9 ===
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=== Page 1 ===
From:
(USANYS) 6"
To:
(USANYS)"
Subject: Re: Law360
Date: Thu, 11 Feb 2021 14:56:44 +0000
Thanks,
.
Do you mind letting me know if you get more inquiries on this, including from other outlets?
(Bloomberg has been contacting me, and I've been ignoring.)
On Feb 11, 2021, at 8:34 AM,
(USANYS)
wrote:
I meant I *won't share further!
Excited for you, and good luck!!
Sent from my iPhone
On Feb 11, 2021, at 8:32 AM,
(USANYS) 6
wrote:
Thanks,
I appreciate it.
On Feb 11, 2021, at 8:28 AM,
(USANYS)
wrote:
I obviously include this in clips or share further.
Just thought you'd want to see this if you already hadn't.
Sent from my iPhone
Begin forwarded message:
Fr
Da
To
Co
Subject: Law360
3 Names To Watch As Biden Mulls Next SDNY Top
Prosecutor
By Pete Brush
Sent from my iPhone
EFTA00032872

=== Page 2 ===
Share us on:
Law360, New York (February 10, 2021, 5:41
PM EST) -- President Joe Biden is ramping
up the process of choosing new top federal
prosecutors across the country, and while he
may not rush to replace Manhattan U.S.
Attorney Audrey Strauss, lawyers have their
eye on a handful of her potential successors.
The application process to helm the U.S.
Attorney's Office for the Southern District of
New York, a process that court-watchers say
is active and includes a large pool of
candidates, comes as the Biden
administration begins the work of replacing
U.S. attorneys appointed by former President
Donald Trump, who have all been asked to
step down.
But the president may not hurry to replace
Strauss, who in December was formally
appointed as U.S. attorney by federal judges
amid the chaos of the outgoing Trump
administration.
Strauss, who of late has brought high-profile
cases including sex-abuse charges against
Jeffrey Epstein associate Ghislaine
Maxwelland ex-fashion executive Peter
Nygard, is well-regarded, and her presence
leaves the White House the luxury of taking
its time on SDNY if it wishes to prioritize
dozens of other districts across the country.
"She has a stellar reputation inside and
outside the office," Pace Law School
professor Bennett L. Gershman said of
EFTA00032873

=== Page 3 ===
Strauss.
Nevertheless the application process is
underway in the Southern District, sources
said, with Senate Majority Leader Chuck
Schumer, D-N.Y., holding powerful sway over
the process. Asked to handicap top possible
successors, lawyers named three people:
Damian
Williams is a veteran SDNY
prosecutor who heads the district's Securities
and Commodities Fraud Task Force. He
prosecuted former politicians Sheldon Silver
and Chris Collins in recent years, and is
widely regarded as a steadying presence
inside the halls at 1 St. Andrew's Plaza.
Williams, who would be the first Black person
to head the office, is a former law clerk for
D.C. Circuit Judge Merrick B. Garland,
Biden's nominee for attorney general who is
slated for a Feb. 22 confirmation hearing in
the Senate.
The Garland clerk chain, dozens strong,
could be fertile ground for possible picks,
lawyers said, on the theory that a pre-existing
relationship with the man who likely will lead
Biden's Department of Justice could be
valuable.
Katherine Goldstein
A white collar partner at Akin Gump Strauss
Hauer & Feld LLP, Katherine Goldstein is a
former SDNY Securities and Commodities
EFTA00032874

=== Page 4 ===
Fraud Task Force chief with a sharp legal
mindwho has worked on modernizing and
improving insider trading enforcement. She
has handled a number of high-profile white
collar fraud cases.
After Strauss and Mary Jo White, who held
the post from 1993 until 2002, Goldstein
would be the third woman to take the job in its
more-than 200 year history, if confirmed.
Anjan Sahni
Like Williams and Goldstein, Anjan Sahni, a
WilmerHale white collar partner, is a former
SDNY Securities and Commodities Fraud
Task Force chief.
Sahni, who is of South Asian descent, also is
noted for his work on a defense team
that won acquittal for Citigroup trader Rohan
Ramchandani in a closely-watched forex-
rigging criminal trial.
Williams, Goldstein and Sahni are all said to
be friendly with, and have professional ties to,
former Manhattan U.S. Attorney Preet
Bharara, who was fired by the Trump
administration in 2017. Sources said Bharara
has a direct line to Schumer as the
application process unfolds.
--Editing by Jill Coffey.
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=== Page 1 ===
Do you have any emails where you said Epstein needed a cellmate? Or any other emails concerning Epstein. If so can you please
print them and give them to me.
Forensic Psychologist
LCDR United States Public Health Service
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Fax-
email-
CONFIDENTIAL
SDNY_00009826
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=== Page 1 ===
FEDERAL DEPARTMENT BUREAU OF DEPARTMENT JUSTICE
UNITED STATES GOVERNMENT
MEMORANDUM
Metropolitan Correctional Center, New York, New York
DATE:
August 10th, 2019
TO:
Lieutenant
FROM:
Correctional Officer
SUBJECT: Response to Institution
On August 10, 2019 at approximately 8:45 am I, Officer
responded to MCC NY
at the request of the Operations Lieutenant for emergency hospital detail. Upon arriving I
was detail to New York Presbyterian hospital room A9 in emergency room where inmate
Epstein, Jeffrey # 76318-054 remains where located. I was responsible for watching the
remains until further instruction was given along with another correctional officer. Shortly
thereafter Institution Duty Officer (IDO) arrived and took command of detail. The timeline
for detail is as followed (times are approximate)
1030 Remains was prepared by hospital staff to be moved to hospital morgue
1045 Hospital staff escort remains to hospital morgue area cooling unit
1050 Area is ensured as secure by officers on detail at direction of IDO
1135 IDO communicates with Director
of Office of City Medical Examiner
(OCME) in regards to receiving remains to be transported to city morgue
1137 A/W notified by IDO
1138 IDO attempts to communicate with Director
of OCME (left message)
1139 IDO receives return communication from Director
(OCME)
1204 IDO receives communication from A/W
1208 IDO receives communication from A/W in regards to instruction on remains
1210
IDO communicates with Director
of OCME and coordinate movement
1257 Staff from OCME depart from New York Presbyterian hospital and transport
remains to city morgue location
1303 Hospital detail staff arrive back at MCC New York
Federal Correction Officer
US Dept of Justice
Federal Bureau of Prisons
MCC-NewYork
CONFIDENTIAL
SDNY_00009477


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Re: Moore murder
Date: Wed, 10 Jul 2019 01:56:55 +0000
Importance: Normal
Amazing. Thank you!
On Jul 9, 2019, at 9:38 PM,
(USANYS)
wrote:
Sure can!
From:
Sent: Tuesday, July 9, 2019 8:35 PM
To:
(USANYS)
Subject: Moore murder
Hey there,
Sorry we haven't been able to connect in a while. Are you still able to handle the immunity package for LEXUS and RICO
memo for the VICAR murder charge against J-Rock and Sauce? I'm totally swamped with this Epstein stuff and won't be
able to turn to that stuff until next week at the earliest. Would be amazing if you could handle.
Thanks very much,
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=== Page 1 ===
From: Public Policy Law360 <news@law360.com>
To:
Subject: Supreme Court Leads At 1st Trump-Biden Debate
Date: Wed, 30 Sep 2020 08:47:01 +0000
Law360 Public
Policy
PUBLIC POLICY
How does your salary stack up to your peers?
Take our survey.
Wednesday, September 30, 2020
Follow Law360
TOP NEWS
LexisNexis
Supreme Court Leads At 1st Trump-Biden Debate
President Donald Trump and Democratic nominee Joe Biden jousted over
the U.S. Supreme Court at their unruly first debate Tuesday, disagreeing over
Law360 Rising Stars
when to fill a vacant seat and whether Biden should address liberal proposals
to add more justices.
1 document attached
Read full article
Trump, Biden Fight Over Climate Change In Heated 1st Debate
President Donald Trump and former Vice President Joe Biden fought over
energy and environmental policies during the first presidential debate
Tuesday, with Trump defending his push to relax emissions rules in an effort
to make cars more affordable and Biden vowing to reenter the Paris accord
as president.
Read full article
Flynn Atty Invokes Executive Privilege Over Trump Meeting
A D.C. federal judge forced Michael Flynn's lead defense attorney to admit
LAW FIRMS
Tuesday she has personally discussed the former national security adviser's
criminal case with President Donald Trump recently, just moments after she
Ademi & O'Reilly
invoked executive privilege to avoid speaking about the nature of her
Ahdoot & Wolfson
conversations.
Akerman LLP
Read full article
Akin Gump
Arnold & Porter
Analysis
Baker Botts
Will Barrett Deliver Pivotal Vote To Strike Down The ACA?
Berger Montague
Democrats are understandably scared that Judge Amy Coney Barrett will
Berman Tabacco
vote to vaporize the Affordable Care Act if she joins the U.S. Supreme Court.
But whether she'll actually do so, much less deliver a decisive fifth vote
Blank Rome
against the landmark law, is far from clear.
Bleichmar Fonti
1 document attached Read full article
Brennan Manna
Bryan Cave Leighton Paisner
Analysis
Burns Bowen Bair
What Employers Should Know About New NY Sick Leave Law
As New York employers adapt to the state's new paid sick leave law, which
Consovoy McCarthy
goes into effect Wednesday, they should note the legislation's wide scope
Cowper Law
and its overlap with existing paid leave laws, attorneys say.
Crowell & Moring
EFTA00032633

=== Page 2 ===
Read full article
Cummins Law LLC
Calif. Judge Blocks Upcoming Immigration Fee Hikes
DLA Piper
A California federal judge on Tuesday barred the federal government from
Daniels & Tredennick
raising immigration application fees just days before the changes were set to
Davis Graham
take effect, finding that acting Homeland Security chief Chad Wolf was likely
improperly appointed.
Debevoise & Plimpton
Opinion attached Read full article
DiCello Levitt
Dillon McCandless
Ga. Told To Back Up Voting Machines With Paper Ballots
Donahue Goldberg
Georgia must provide paper backups of updated voter information for the
Duval & Stachenfeld
Nov. 3 election to reassure electors its malfunction-plagued digital system
Earthjustice
can be easily bypassed if necessary, an Atlanta federal judge ruled Monday.
Edelson PC
Order attached Read full article
Epstein Becker Green
BANKING & SECURITIES
Gibbons PC
Harvey & Binnall
Analysis
Holland & Knight
Barrett May Reinforce High Court Trends For Banking Industry
Husch Blackwell
Seventh Circuit Judge Amy Coney Barrett's elevation to the U.S. Supreme
Ichter Davis
Court would position her to weigh in on fintech regulation, agency
Jackson Lewis
independence and other legal issues affecting the banking industry. But with
the high court already showing a tilt toward business, her addition to the
Jenner & Block
bench may not yield a sea change from a financial services perspective.
Jones Day
Read full article
Katten
Keating Muething
ENERGY & ENVIRONMENTAL
Keller Landsberg
Analysis
King & Spalding
FERC To Take On Carbon Pricing's Place In Power Markets
Kirkland & Ellis
The Federal Energy Regulatory Commission is trying to figure out how state
Krevolin & Horst
efforts to charge polluters for carbon emissions can mesh with the agency's
Lanier Law Firm
mandate to level the playing field in its wholesale power markets and keep
Latham & Watkins
prices reasonable for consumers.
Read full article
Law Offices of Alan S. Futerfas
Levi & Korsinsky
EPA Tells DC Circ. There's No Harm In Methane Regs Rollback
McDermott Will
The U.S. Environmental Protection Agency has asked the D.C. Circuit not to
McDonald Hopkins
pause the Trump administration's less restrictive policy on methane
McGuireWoods
emissions from new and modified oil and gas infrastructure, arguing the
Milbank LLP
challengers are exaggerating any harm the changes will bring.
2 documents attached Read full article
Mintz Levin
Morgan Lewis
EPA Waves Caution Flag On Calif.'s Zero-Emission Car Plan
Morrison & Foerster
The head of the U.S. Environmental Protection Agency is looking to short-
Mukasey Frenchman
circuit the California governor's plan to ban the sale of gas-powered
Murray Murphy Moul & Basil
automobiles by 2035, saying the state is currently having trouble meeting its
Orrick
electricity needs and may need EPA approval.
Letter attached Read full article
Patterson Belknap
Paul Hastings
HEALTH & LIFE SCIENCES
Polsinelli
Pomerantz LLP
Health Care Clashes Dominate 1st Trump-Biden Debate
Potter Minton
In the first of three debates, President Donald Trump and former Vice
Quinn Emanuel
President Joe Biden on Tuesday waged a bitter battle that saw wide-ranging
Robbins Geller
domestic policy topics repeatedly distilled down to the coronavirus pandemic,
the Affordable Care Act and abortion rights.
Robbins Ross
Read full article
Sanford Heisler
Selendy & Gay
Catalyst Loses Fight Against FDA Approval Of Rival's Drug
Seyfarth Shaw
EFTA00032634

=== Page 3 ===
A Florida federal judge axed Catalyst Pharmaceuticals Inc.'s suit claiming the
Sidley Austin
U.S. Food and Drug Administration unlawfully approved a lower-cost version
Snell & Wilmer
of a drug that treats a rare autoimmune disease, rejecting Catalyst's
Spilman Thomas
challenge against a magistrate judge's ruling.
Opinion attached Read full article
Squire Patton Boggs
Dillon McCandless Seeks $136K Fee From Pa. For Virus Fight
Steptoe & Johnson LLP
Stroock & Stroock
Dillon McCandless King Coulter & Graham LLP, which represented a group
of Pennsylvania counties, businesses and lawmakers in a suit that
Sullivan & Cromwell
overturned Gov. Tom Wolf's pandemic-related closure orders and crowd
Taylor English
limits, is now asking the federal court to make the state pay their $136,000 in
Wilson Elser
legal fees.
2 documents attached Read full article
COMPANIES
23andMe Inc.
Coronavirus Regulations: A State-By-State Week In Review
Amazon.com Inc.
President Donald Trump's reelection campaign continued to lock horns with
American Airlines Group Inc.
governors fighting the COVID-19 pandemic this week, with New Jersey
American Automobile Association
defending lawsuits over the state's remote-voting plan and Pennsylvania
Inc.
seething over a crowded rally the president held there recently.
Read full article
American Civil Liberties Union
American Federation of State
IP & TECHNOLOGY
County & Municipal Employees
American Immigration Lawyers
PureShield Says Allied Bio Coronavirus Disinfectant Infringes
Association
Chemical company PureShield Inc. claimed in a lawsuit filed Monday in
American Petroleum Institute Inc.
Texas federal court that Allied BioScience Inc.'s SurfaceWise 2 surface
Ancestry.com LLC
disinfectant, which advertises protection against COVID-19 for up to seven
Apple Inc.
days, infringes on 10 of PureShield's patents.
Arch Coal Inc.
Complaint attached Read full article
BNP Paribas SA
MEDIA & ENTERTAINMENT
Backcountry.com
BancWest Corp.
Snowden Ordered To Pay $5M For Revealing Classified Info
Bank of America Corp.
A Virginia federal court on Tuesday ordered former U.S. intelligence
Barclays PLC
contractor Edward Snowden to hand over more than $5 million that he
Celgene Corp.
allegedly earned from book sales and speaking engagements in which he
revealed classified information without permission.
Center for Biological Diversity
Order attached Read full article
Center for Justice
Charming Shoppes, Inc.
INSURANCE
Chipotle Mexican Grill Inc.
Citigroup Inc.
LA Nightclub Says Virus Triggers 'Physical Loss' Insurance
Clean Air Task Force
A Los Angeles nightclub is asking a California federal court not to throw out
Commonwealth Edison Co.
its proposed class action alleging its insurer wrongly denied it coverage for
Communications Workers of
losses stemming from the COVID-19 pandemic, saying the virus caused a
America
physical loss by curtailing its business.
Consumer Bankers Association
Response attached Read full article
Cox Communications Inc.
REAL ESTATE
Cox Enterprises
Credit Suisse Group AG
Analysis
Deutsche Bank AG
Opportunity Zone Order May Not Attract Private Investment
Environmental Defense Fund Inc.
President Donald Trump's executive order directing the government to
Environmental Integrity Project
prioritize opportunity zones when building and leasing properties shows a
desire to attract investment in the areas but may do little to lure private
Exelon Corp.
capital on its own.
Facebook Inc.
1 document attached
Read full article
Federal National Mortgage
Association
Latham Reps COVID-19 Mall Closure Suit Against LA County
FirstEnergy Corp.
EFTA00032635

=== Page 4 ===
Latham & Watkins LLP is leading the charge representing plaintiffs in a
Freddie Mac
putative class action filed Monday accusing Los Angeles County of violating
Geico
the constitutional rights of hundreds of indoor mall businesses that were
forced to close amid the coronavirus pandemic, costing them millions in lost
Georgia State University
wages and revenue.
Google Inc.
Complaint attached Read full article
HSBC Holdings PLC
EMPLOYMENT & BENEFITS
Homes.com Inc.
Hornor Townsend & Kent Inc.
III. Union Tells 7th Circ. It Shouldn't Have To Rep Nonmembers
ISO New England Inc.
A Seventh Circuit judge on Tuesday said he was concerned that an Illinois
Immigrant Legal Resource Center
engineering union arguing that it should be exempted from exclusively
Institute for Fiscal Studies
representing nonmembers in grievance proceedings was simply asking the
court to issue "an advisory opinion," in the absence of a more detailed claim.
J.C. Penney Co. Inc.
Read full article
JPMorgan Chase & Co.
LexisNexis Group
Workers And Advocates Fight NLRB Union Contact Proposal
Linkedln Corp.
Withholding employees' email addresses and cellphone numbers from unions
Los Angeles County Employees
deprives workers of information and tips the organizing scales in employers'
Retirement Association
favor, workers, unions and others said ahead of a Monday deadline for
Macmillan Publishers Ltd.
comments on a proposed National Labor Relations Board rule change.
Read full article
Marriott Vacations Worldwide Corp.
Mazars LLP
Heeding Dem Subpoena Would Hurt NLRB, Agency Atty Says
Merck & Co. Inc.
Making the National Labor Relations Board release records of its "joint
Morgan Stanley
employer" policy development would undermine its candor in future
National Right to Work Legal
deliberations, the board's top legal adviser said Tuesday in answer to a U.S.
Defense Foundation
House of Representatives subpoena seeking the inside scoop on the
Natural Resources Defense
agency's regulatory pivot.
Council
Letter attached Read full article
New Civil Liberties Alliance
New York Civil Liberties Union
COMPETITION
New rue21 LLC
Peabody, Arch Drop Merger Plans After Judge Sides With FTC
PJM Interconnection LLC
Arch Resources and Peabody Energy Corp. on Tuesday abandoned a
Parlux Fragrances Inc.
proposed joint venture after a Missouri federal court said the companies
Peabody Energy Corp.
couldn't rebut the Federal Trade Commission's claim their combination would
Penn Mutual Asset Management
result in the loss of "meaningful coal-on-coal competition."
Inc.
Read full article
Penn Mutual Life Insurance Co.
CYBERSECURITY & PRIVACY
Perfumania Holdings Inc.
Procter & Gamble Co.
Calif. Gov. Vetoes Genetic Testing Privacy Bill
RaceTrac Petroleum
California Gov. Gavin Newsom vetoed a proposed state law that would
Regions Financial Corp.
establish privacy protections over the data collected by genetic testing
Roku Inc.
companies like Ancestry.com and 23andMe, saying that it could interfere with
laboratories' mandate to report COVID-19 test results.
SUNY Upstate Medical University
Sierra Club
Letter attached Read full article
Skype Technologies SA
CONSUMER PROTECTION
SoftBank Group Corp.
SolutionPoint International Inc.
Series
SoulCycle Inc.
AGs In A Pandemic: Grewal Talks NJ Price-Gouging
Spectrum Management Holding
New Jersey Attorney General Gurbir Grewal explains how his office adapted
Co.
its enforcement playbook to unexpected challenges in order to crack down on
Standard Chartered PLC
unconscionable pricing amid the pandemic.
Read full article
State Teachers Retirement System
of Ohio
TCPA's Autodialer Ban Fails Constitutional Test, Court Told
Target Corp.
Tenet Healthcare Corp.
EFTA00032636

=== Page 5 ===
Real estate portal Homes.com is mounting a constitutional challenge to the
The Lawyers' Committee for Civil
Telephone Consumer Protection Act's broad prohibition on using autodialers
Rights Under Law
to contact consumers without consent, arguing that numerous deficient
The New York Times Co.
exemptions to that prohibition and widespread uncertainty over what
constitutes an autodialer warrant striking down the litigation-fueling
The State University of New York
provision.
The University of Alabama System
2 documents attached Read full article
TikTok Inc.
INTERNATIONAL TRADE
Topa Insurance Co.
Trump Organization Inc.
Blueberry Imports Could Be Next On Trump's Tariff List
Twitter Inc.
The Trump administration called for an investigation of imported blueberries
U.S. Chamber of Commerce
on Tuesday, setting the stage for potential new tariffs as part of a broader
UBS AG
White House strategy to address surging imports of perishable food.
United Steelworkers
Letter attached Read full article
Virginia Community College
System
TAX
Wal-Mart Stores Inc.
Biden Vows To Undo Tax Cuts, Trump Touts Record In Debate
Washington Post Co.
Former Vice President Joe Biden promised to repeal the 2017 tax law during
YouTube Inc.
Tuesday night's debate with President Donald Trump, who touted his
Zoom Video Communications Inc.
economic record without directly saying whether he paid only $750 in federal
income taxes in 2016 and 2017.
GOVERNMENT AGENCIES
2 documents attached Read full article
Bureau of Citizenship and
Immigration Services
Manhattan DA Says 2nd Circ. Stayed Trump Tax Subpoena
California Air Resources Board
The Manhattan district attorney told the Second Circuit on Tuesday that it
California Department of Public
cannot enforce a subpoena against President Donald Trump's accounting
Health
firm for years of tax and business records until an appeal has concluded.
California Health and Human
2 documents attached Read full article
Services Agency
California Public Employees'
Think Tank Says UK Tax Base Shaky From Pandemic, Brexit
Retirement System
The economic effects of both the coronavirus pandemic and the decision to
Central Intelligence Agency
leave the European Union means that the United Kingdom's tax base is now
Consumer Financial Protection
more uncertain than ever, the leading nonpartisan British fiscal think tank
Bureau
said Tuesday.
European Union
1 document attached
Read full article
Executive Office for Immigration
Review
BANKRUPTCY
Executive Office of the President
House Panel Advances Bill To Limit Exec Bonuses In Ch. 11
Federal Bureau of Investigation
The House Judiciary Committee advanced a Democrat-backed bill to the full
Federal Communications
chamber Tuesday that would limit the bonuses doled out to senior executives
Commission
of companies in Chapter 11 while improving protections for the benefits of
Federal Energy Regulatory
rank-and-file workers in bankruptcy, a measure touted as a necessary
Commission
remedy for inequalities in the restructuring process.
Federal Housing Finance Agency
Bill attached Read full article
Federal Reserve System
Federal Trade Commission
6 Law Firms Vie To Head FirstEnergy Shareholder Suit
Food and Drug Administration
Six law firms have put their hats in the ring to be selected as lead counsel in
a proposed consolidated class action against utility company FirstEnergy
Gila River Indian Community
over allegations that news the company paid Ohio lawmakers $60 million to
Illinois Attorney General's Office
arrange a $1 billion bailout sent stock plummeting.
Internal Revenue Service
Motion attached Read full article
International Trade Commission
National Labor Relations Board
IMMIGRATION
National Security Agency
Navajo Nation
Judges Reject DOJ's 'Frivolous' Bid To Pause Census Ruling
New Jersey Department of Health
EFTA00032637

=== Page 6 ===
A trio of federal judges on Tuesday refused to temporarily lift their ruling
New York State Department of
barring the Trump administration from excluding unauthorized immigrants
Financial Services
from the census count, slamming the government's request for reprieve as
Office of the Comptroller of the
"frivolous" and "meritless."
Currency
Order attached Read full article
Ohio House of Representatives
DOJ May Allow Attys To Help Pro Se Immigrants With Docs
Oklahoma Supreme Court
The U.S. Department of Justice may soon allow immigration attorneys to help
U.S. Army
people facing deportation fill out briefs and forms without representing the
immigrants for the rest of the proceedings, a change that could increase
U.S. Attorney's Office
access to counsel in immigration court.
U.S. Census Bureau
Notice attached Read full article
U.S. Court of Appeals for the
District of Columbia Circuit
Salvadoran Couple Fit For Residency, Despite Illegal Entry
U.S. Court of Appeals for the
A Salvadoran couple living in the U.S. under the Temporary Protected Status
Second Circuit
program may obtain green cards after a Minnesota federal judge rejected the
U.S. Court of Appeals for the
government's arguments that their initial illegal entry left them ineligible for
Seventh Circuit
permanent residency.
U.S. Department of Commerce
Opinion attached Read full article
U.S. Department of Defense
U.S. Department of Health and
Census-Takers Say Gov't Ending Count, Defying Court Order
Human Services
The U.S. Census Bureau has said it intends to complete its decennial count
U.S. Department of Homeland
by Oct. 5, after a whistleblower warned a California federal judge that the
Security
agency was disregarding her order to not end data collection by Sept. 30.
U.S. Department of Justice
2 documents attached Read full article
U.S. District Court for the Central
District of California
Cities, Feds Spar Over Constitution's Language In Census Suit
U.S. District Court for the District of
Lawyers for the Trump administration and a group of cities and nonprofit
Columbia
organizations tussled over the language of the 14th Amendment before a
U.S. District Court for the District of
three-judge panel in D.C. federal court Tuesday, in a lawsuit over the
Connecticut
president's effort to exclude unauthorized immigrants from the final census
count.
U.S. District Court for the District of
Minnesota
Read full article
U.S. District Court for the District of
WHITE COLLAR
New Jersey
U.S. District Court for the Eastern
Ex-ComEd Exec Cops To Bribery Scheme Tied To III. Speaker
District of Missouri
A former Commonwealth Edison Co. executive pled guilty in Illinois federal
U.S. District Court for the Eastern
court Tuesday to participating in a bribery conspiracy in which he paid off a
District of Texas
powerful Illinois legislator in exchange for the lawmaker's influence on
U.S. District Court for the Eastern
legislation that affected the electric company's business.
District of Virginia
1 document attached Read full article
U.S. District Court for the Northern
District of California
TELECOMMUNICATIONS
U.S. District Court for the Northern
District of Georgia
FCC Forecasts 4 Spectrum Auctions Over Next Year
U.S. District Court for the Northern
The Federal Communications Commission is tentatively planning on holding
District of Illinois
at least three other spectrum auctions in the next fiscal year on top of the
U.S. District Court for the Southern
long-awaited C-Band auction slated for December, the agency has
District of Florida
announced.
U.S. District Court for the Southern
Notice attached Read full article
District of New York
U.S. District Court for the Western
House Passes Bill To Block Home Number Switch After Crisis
District of Pennsylvania
The U.S. House of Representatives approved a bill Tuesday to ensure that
U.S. Environmental Protection
people whose houses are destroyed in emergencies such as fires and
Agency
hurricanes won't lose their assigned home phone numbers.
U.S. General Services
Read full article
Administration
Senate Pair Floats Section 230 Limits For Illegal Online Posts
EFTA00032638

=== Page 7 ===
A bipartisan pair of senators added to the pile of nearly a half-
U.S. House Committee on Energy
dozen bills seeking to narrow Section 230 of the Communications Decency
and Commerce
Act, saying Tuesday that they want websites to be held more accountable for
U.S. House of Representatives
reporting potentially illegal activity.
U.S. Patent and Trademark Office
Bill attached Read full article
U.S. Supreme Court
CANNABIS
United States District Court for the
Southern District of Ohio
Oklahoma Supreme Court Kills Legal Pot Ballot Initiative
The Oklahoma Supreme Court has removed a recreational marijuana
legalization initiative from the November ballot, saying the gist of the
measure that would have been presented to voters didn't convey the actual
proposal.
Petition attached Read full article
Mich. AG Probing Marijuana Bait-And-Switch In Petition Push
Michigan's attorney general said a group gathering petition signatures to strip
the governor's emergency powers may have misled voters by telling them the
push was related to a medical marijuana initiative, among other issues.
Read full article
NJ Podiatrist Loses Fight Over Medical Pot Prescriptions
A New Jersey podiatrist who was banned from prescribing medical marijuana
lost his bid to sue state regulators on Monday after a judge said his claims of
discrimination fail because podiatrists can't actually prescribe pot in the state.
Opinion attached Read full article
EXPERT ANALYSIS
Opinion
Digital Platform Agency Would Imperil Internet Commerce
Rather than help consumers, former Federal Communications Commission
Chairman Tom Wheeler's recent proposal for a Digital Platform Agency to
regulate internet business practices would cement dominant platforms'
market power, adversely affect investment, and risk the most innovative U.S.
sector's health, says Thomas Lenard at the Technology Policy Institute.
Read full article
NY Gendered Pricing Law May Have Limited Effect
The New York gendered pricing law, effective Wednesday, may not achieve
its aim of preventing price discrimination in goods and services based on the
gender of their intended consumer due to potential loopholes in the law's
definitions, a broad safe harbor for businesses, and the lack of a private right
of action, say Mark Ciani and Sean Akchin at Katten.
Read full article
FERC Order Could Open Electric Grid To Diverse Resources
The Federal Energy Regulatory Commission's recent order addressing
distributed energy resources' participation in electric power markets could
transform the power grid by integrating everything from small solar
installations to smart water heaters and electric vehicles, say Levi McAllister
and Arjun Ramadevanahalli at Morgan Lewis.
Read full article
Law Firm Social Responsibility Strategies In The New Normal
Law firm leaders and marketers should consider several fundamental
questions as they develop their corporate social responsibility programs amid
the pandemic with reduced available time, money and personnel, including
identifying a realistic charitable spending budget and seeking input from firm
EFTA00032639

=== Page 8 ===
lawyers, clients and nonprofit partners, says Tina van der Ven at NewStar
Media.
Read full article
LexisNexis
LEGAL INDUSTRY
Analysis
In JPMorgan Deal, DOJ Puts Spotlight On Compliance Tech
In the deferred prosecution deal with JPMorgan Chase & Co. announced
Tuesday, federal prosecutors made clear that they now expect companies
and their in-house counsel to bring data analysis into corporate compliance.
Read full article
DLA Piper Escapes Tech Co.'s Malpractice Suit
A technology company has dropped DLA Piper's Canadian arm and two
individual attorneys from a malpractice suit over a patent application process
that went sour, effectively ending the case in Florida federal court.
Read full article
Jones Day Fights Atty's Bid To Revive Equal Pay Claim
Jones Day has told a D.C. federal judge to stick with his decision to toss a
former associate's Equal Pay Act claim, insisting the attorney hasn't shown
she tackled the same workload as her higher-paid male peers.
Read full article
Exclusive
JPMorgan, Goldman GCs Up The Ante On Diversity Promises
Amid civil unrest over racial injustices in the U.S., top in-house lawyers from
JPMorgan Chase & Co., Goldman Sachs, Bank of America and nine other
global financial institutions have pledged to further their commitment to
diversity efforts in the legal profession, outlining a list of goals for themselves
and their peers in an open letter shared Tuesday with Law360.
Read full article
Bryan Cave Snags High Court Practice Co-Chair From Sidley
Sidley Austin LLP's West Coast head of the firm's appellate and supreme
court group has moved to Bryan Cave Leighton Paisner LLP, his new firm
announced Tuesday.
Read full article
Jay-Z's Files Unsealed In Perfume Case As Secrecy Bid Fails
A New York state judge declined to seal a large cache of documents
belonging to Jay-Z on Tuesday in a lawsuit that claims the rap icon didn't
promote a perfume as promised, only letting him redact information like his
phone number from a personal schedule.
Read full article
The Top In-House Hires Of September
Legal department hires during September included high-profile appointments
at Zoom, AAA and BroadwayHD. Here, Law360 looks at some of the top in-
house announcements from the past few weeks.
Read full article
Northern District Of Ga. Says No Jury Trials Until 2021
As coronavirus levels stay high in Georgia, the federal district that includes
Atlanta said Tuesday it will hold no jury trials before next year, including high-
EFTA00032640

=== Page 9 ===
profile showdowns like the $400 million kickbacks case against two former
Tenet Healthcare Corp. executives.
Read full article »
JOBS
Search full listings or advertise your job opening
Executive Director, National Homelessness Assistant City Attorney
Law Center
City of Oxnard, California
National Homelessness Law Center
Oxnard, California
Washington, District of Columbia
Staff Attorney, Toxic Exposure and Health
Director of Strategic Legal Advocacy
Program
Earthjustice
Earthjustice
Washington, DC or San Francisco, -
New York, New York
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EFTA00032641


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=== Page 1 ===
Ok got it!
>>>
8/10/2019 10:17 PM >>>
I have the actual bog in case we need it later.
Associate Warden
MCC New York
150 Park Row
New York NY 10007
>>> Tijuana Doctor 8/10/2019 9:59 PM >>>
Thank you!
>>>
8/10/2019 9:59 PM >>>
see attachment:
Associate Warden
MCC New York
150 Park Row
New York, NY 10007
CONFIDENTIAL
SDNY_00009159
EFTA00033705


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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com>
To:
Subject: DOJ Eyes Fraud Section Acting Chief For Permanent Gig
Date: Tue, 16 Jul 2019 07:50:53 +0000
Law360 White
Collar
WHITE COLLAR
Tuesday, July 16, 2019
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
DOJ Eyes Fraud Section Acting Chief For Permanent Gig
Robert Zink, the acting chief of the U.S. Department of Justice's Fraud
Section, is expected to be tapped as permanent head of the corporate crime-
fighting unit, sources familiar with the matter have confirmed to Law360.
Read full article
Epstein Accusers Appear At Bail Hearing, Ask He Be Jailed
The government sparred with sex-trafficking suspect Jeffrey Epstein at a bail
hearing on Monday, decrying his "offensive" arguments it said minimized the
charges - arguments punctuated by pleas to jail him from two women who
say Epstein had victimized them.
Read full article
Listen to our new podcast here
PR Exec Files As Foreign Agent After Callout In Craig Case
LAW FIRMS
A London public relations executive expected to take the stand as a
Akin Gump
prosecution witness at the upcoming trial of former Skadden partner Gregory
Craig registered Friday with the U.S. Department of Justice as a foreign
Bayard PA
agent of Ukraine.
Campbell & Williams
Read full article
Cleary Gottlieb
Cosgrove Eisenberg
DOJ Urges 'Rigorous' Conflict Inquiry In 'Varsity Blues' Case
Covington & Burling
Federal prosecutors have again urged a Boston federal judge overseeing the
Davis Polk
"Varsity Blues" college admissions cheating case to hold a "rigorous inquiry"
into conflicts of interest at BigLaw firms representing parents and the
Donnelly Conroy
University of Southern California.
Eisner Gorin
Read full article
Freedman + Taitelman
Gellert Scali
Couple Can Get Separate Trials In Fraud Suit, 3rd Circ. Says
Gibson Dunn
The Third Circuit has ordered a new trial for a woman convicted alongside
Gupta Wessler
her husband in Pennsylvania federal court in a benefits fraud case after
finding that she'd been improperly forced to choose between taking the stand
Hogan Lovells
in her own defense and exercising her privilege not to testify against her
Horack Talley
spouse.
Hughes Hubbard
Opinion attached Read full article
Katten Muchin
Kaye McLane
HBO 'Neverland' Arbitration Row Paused In Anti-SLAPP Effort
Kinsella Weitzman
A California federal judge on Monday held back on deciding whether the
Latham & Watkins
estate of Michael Jackson's breach of contract suit over HBO's "Leaving
Neverland" documentary should go to arbitration right away, instead allowing
Mark Beck Law
HBO to address First Amendment issues underlying the allegations it
Motley Rice
disparaged Jackson's character.
Nixon Peabody
EFTA00032956

=== Page 2 ===
Read full article
O'Melveny & Myers
SECURITIES
Offit Kurman
Pepper Hamilton
Nomura Settles SEC's Shoddy Supervision Claims For $26.5M
Richards Layton
Nomura agreed Monday to pay more than $26 million to resolve the U.S.
Robbins Geller
Securities and Exchange Commission's allegations that the bank failed to
supervise traders who allegedly lied to clients about the pricing of residential
Ropes & Gray
mortgage-backed securities and commercial mortgage-backed securities.
Scheper Kim
2 documents attached Read full article
SeegerWeiss
Skadden
SEC Settles With Broker In Woodbridge Ponzi Scheme
Stradley Ronon
The U.S. Securities and Exchange Commission settled claims Monday with a
Wachtell Lipton
Tennessee-based broker the agency accused of selling unregistered
securities in connection with two Ponzi schemes, including the $1.2 billion
Weil Gotshal
scheme allegedly perpetrated by the Woodbridge Group of Cos. LLC.
WilmerHale
2 documents attached | Read full article
Zuckerman Spaeder
Venezuelans Hit Gem-Tied Crypto Co. With $30M Ponzi Suit
COMPANIES
A group of Venezuelan nationals filed a fraud suit in Florida federal court on
Barnes & Noble Inc.
Friday, claiming they were reeled into a $30 million Ponzi scheme with
Clinique Laboratories LLC
promises of lofty returns on investments in a diamond-backed cryptocurrency.
ConvergEx Group LLC
Complaint attached Read full article
Ennis Inc.
Estee Lauder Companies Inc.
Reckitt Hit With Stock Drop Suit Over $1.4B Opioid Probe Deal
FTI Consulting Inc.
British pharmaceutical company Reckitt Benckiser Group PLC was hit with a
Home Box Office Inc.
stock drop suit Monday in New Jersey federal court, shortly after announcing
it will pay U.S. authorities up to $1.4 billion to settle an investigation into an
Indivior PLC
opioid addiction medication.
JPMorgan Chase & Co.
Complaint attached Read full article
National Consumer Law Center
New Jersey On-Line LLC
PUBLIC INTEGRITY
New York Times Co.
New York University
Boston City Aides Make 11th-Hour Bid To Toss Extortion Case
Nomura Holdings, Inc.
Two Boston City Hall aides charged with pressuring a music festival to hire
unneeded union labor made a final bid to get extortion charges thrown out
Pacific Investment Management
Co.
Monday in federal court just a week before jury selection is scheduled to
begin.
Pitney Bowes Inc.
Read full article
Podesta Group Inc.
Purdue Pharma LP
BANK FRAUD
Reckitt Benckiser Group PLC
Feds Say Tribal Immunity No Bar Against Criminal Charges
Tommy Hilfiger Corp.
UBS AG
The federal government told the Third Circuit on Friday that another court's
recent ruling on tribal immunity to civil suits didn't help an attorney and
Woodbridge Group of Cos. LLC
businessman sentenced to jail on criminal charges for helping provide loans
GOVERNMENT AGENCIES
with illegally high interest rates through tribe-owned companies.
Letter attached Read full article
Administrative Conference of the
United States
HEALTH
Department of Commerce
Executive Office of the President
Insys Proposes Novel Gov't Committee Deal In Ch. 11 Case
Federal Bureau of Investigation
Bankrupt drugmaker Insys Therapeutics Inc. reached a deal with a group of
Federal Trade Commission
government entities seeking representation in its Chapter 11 case Monday by
Guidiville Band of Pomo Indians
proposing the formation of a limited-purpose committee of local agencies that
Internal Revenue Service
will be able to participate in plan negotiations.
Read full article
Kalispel Tribe of Indians
Lac Vieux Desert Band of Lake
IMMIGRATION
Superior Chippewa Indians
EFTA00032957

=== Page 3 ===
Tent Rental Biz Used Unauthorized Workers To Make Millions
National Oceanic and Atmospheric
Administration
A Florida tent rental company and its officers allegedly raked in millions while
Securities and Exchange
concealing from federal investigators that their workforce was composed of
Commission
immigrants not authorized to work in the country, U.S. Department of Justice
officials said Friday.
U.S. Attorney's Office
Read full article
U.S. Bankruptcy Court for the
District of Delaware
GOVERNMENT CONTRACTS
U.S. Court of Appeals for the
Federal Circuit
Ex-Navy Official Sentenced To 70 Mos. For Kickback Plot
U.S. Court of Appeals for the
A former civilian senior procurement official has been sentenced in California
Second Circuit
federal court to 70 months in prison for taking $1.2 million in kickbacks and
U.S. Court of Appeals for the Tenth
paying fraudulent invoices for U.S. Navy contracts, prosecutors said Monday.
Circuit
Read full article
U.S. Court of Appeals for the Third
Circuit
TAX
U.S. Department of Energy
U.S. Department of Homeland
10th Circ. Axes Tax Conviction Over Faulty Pro Se Waiver
Security
The Tenth Circuit on Monday vacated a $342,000 judgment against a man
U.S. Department of Justice
convicted of tax evasion and obstruction, saying a Utah federal court did not
properly warn him that he needed to follow federal court rules if he
U.S. District Court for the Central
represented himself.
District of California
Opinion attached Read full article
U.S. District Court for the District of
Massachusetts
PEOPLE
U.S. District Court for the District of
New Jersey
Judge Who Oversaw Sen. Menendez Trial Dies At 86: Report
U.S. District Court for the Southern
U.S. District Judge William H. Walls, who presided over Sen. Bob
District of Florida
Menendez's New Jersey federal jury trial and acquittal for bribery, has died at
U.S. District Court for the Southern
the age of 86, according to a report from NJ.com.
District of New York
Read full article
U.S. Environmental Protection
Agency
EXPERT ANALYSIS
U.S. House of Representatives
U.S. Immigration and Customs
What To Know About Pending Insider Trading Legislation
Enforcement
Recently introduced in the U.S. House of Representatives, the Insider
U.S. Navy
Trading Prohibition Act will represent a potentially significant clarification of
U.S. Senate
U.S. insider trading laws if it proceeds further. And it could be viewed as
extending criminal liability to "reckless" conduct, say attorneys at Cleary.
U.S. Supreme Court
Read full article
United States District Court for the
District of Utah
Federal Agencies Need A Uniform Record-Keeping Process
The administrative record is very important to federal agency litigation - as
showcased in last month's U.S. Supreme Court decision concerning the
addition of a citizenship question to the 2020 census - yet there is no set of
consistent principles to guide agencies in compiling these official records, say
attorneys at WilmerHale.
Read full article
LEGAL INDUSTRY
Conservative Lawyers Slam Trump's 'Ignorant Racist' Tweets
Checks and Balances, a group of conservative and libertarian attorneys, on
Monday tore into tweets in which President Donald Trump suggested four
Democratic congresswomen of color should "go back" to their "crime
infested" countries, condemning the president's "ignorant racist nature" and
calling his rhetoric "a rejection of those founding principles of our nation."
Read full article
EFTA00032958

=== Page 4 ===
Estee Lauder Promotes General Counsel To Vice Chairman
Estee Lauder elevated its executive vice president and general counsel to
the newly created position of vice chairman, a role in which she will continue
to promote women's professional development.
Read full article
Offit Kurman Deal With NC Firm Paves Way For 13th Office
Offit Kurman PA announced Monday that it is entering into an affiliation with
Charlotte-based Horack Talley Pharr & Lowndes PA, allowing the firm to
expand into its 13th office and its first in North Carolina.
Read full article
Gov't Can't Duck Review Of PACER Fee Use, Fed. Circ. Told
A certified class of PACER users has urged the Federal Circuit to find that the
judiciary can review whether the government improperly spent more than
$200 million it collected from fees, saying the government can't rebut their
claims and has resorted to making a "novel" jurisdictional argument that has
no weight.
Read full article
Interview
15 Minutes With Barnes & Noble's General Counsel
Since he officially started working as the first in-house lawyer at Barnes &
Noble in 2000, Brad Feuer said he has done "everything and anything" at the
company. Here, the general counsel discusses e-reading, his answer to
people who suggest bookstores are obsolete, and two of his favorite books.
Read full article
JOBS
Search full listings or advertise your job opening
White Plains insurance boutique seeks
Mid-sized White Plains firm seeks
associate defense litigator
municipal government associate
KLR Davis
KLR Davis
White Plains, New York
White Plains, New York
elite lit boutique II mid level assoc
Schoen Legal Search
New York, New York
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EFTA00032959


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=== Page 1 ===
Suicide Watch
Chronological
Log
Inmate Companions Log
Name of inmate on watch:
Epstem
Register #:
76318.054
Institution:
ONLY ITEMS ALLOWED:
Sack Meal
Suicide Smock/Slippers
Suicide Sleeping Bag
Date Watch Began / Ended
Suicide Mattress
Paper Cup
Soap
Tampons or
Coom Sanitary Belt/Nankin
7/23/19
To be completed by Chief Psychologist at conclusion of watch:
Booklet
of
SWCL - INMATE
CONFIDENTIAL
SDNY_00009534
EFTA00033867

=== Page 2 ===
STAPLE LOCAL PROCEDURES HERE
Check one of the following:
This is the initial log book for this suicide watch.
Enter date and time watch began:
This is a continuation log book for this watch.
Enter date and time this watch book was initiated:
Instructions to Observer:
Document your observations every
minutes.
Legibly print and sign your name at the beginning of your shift.
CONFIDENTIAL
SDNY_00009535
EFTA00033868

=== Page 3 ===
Suicide Watch Observation Log
Name of Inmate
on watch:
Epstein
Reg #: 76318.054
Date: 7/23/19
Time
Observations: Briefly note your observations. Initial all entries.
Initials
1:40Am
I/m Brought Dam to Suicise cell #4
D
1:45Am
2 cc AM
1/m laying ON BED
-
2
2"Am
1/m Silling Cn Bed talking -
y.
1/m him States his cellmak tried to kill
my
2.30m
/m Sitting on be) trying to remember
what Happen
y
2:45 Am
1/m Sitting onl BED
2
3. im
3:15AM
(7 AnJerson takes Pictures of 1/m
1/m Sitting on BeD
D
D
3:30 m
/m Sitting on BED
0
3.45
You Sitting on Bed
D
4:Am
4ir
I/m Sitting on BED
4:30
1/m I/m Siting on BED
Jos
4:45
Standing at Door talking
of
5" om
Yy Sitting out Bed
I/m Standing it Dear folbing
y
5 PAM
5ᵗʰ AM
1/m Stanling Standing it Deer
By
530 Am
Y/m Standing wt Dar
82
1/m Standarry at Par
6"
Hd
2
1/m Standing At Day
2
Note to all observers: Legibly print and sign your name at the beginning of your shift.
1
CONFIDENTIAL
SDNY_00009536
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=== Page 4 ===
Suicide Watch
Chronological
Log
Staff Suicide Watch
Observers Only
Name of inmate on watch:
Epstein, J.
Register #:
76318-054
Institution:
MCC New York
Date Watch Began / Ended
July 23,2019 - July 24, 2019
To be completed by Chief Psychologist at conclusion of watch:
Booklet
of
SWCL - STAFF
CONFIDENTIAL
SDNY_00009537
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=== Page 5 ===
STAPLE LOCAL PROCEDURES HERE
Check one of the following:
This is the initial log book for this suicide watch
Enter date and time watch began:
July 23,2019 at 1:40AM
This a continuation log book for this watch.
Enter date and time this watch book was initiated:
Instructions to Observer:
Document your observations every 15
minutes.
Legibly print and sign your name at the beginning of your shift.
CONFIDENTIAL
SDNY_00009538
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=== Page 6 ===
Name Epstein of Inmate
Suicide Watch Observation Log
on watch:
Reg #: 76318-054 Date: 7/23/19
Time
Observations: Briefly note your observations. Initial all entries.
Initials
1:40AM
Inmate brought down to suicide cell#4
1:45AM
Inmate lying on bed
2:00AM
Inmate Sitting on bed talking
2:15AM
Inmate states his celimate tried to killhim
2:30AM
Inmate sitting on bed trying to remember
what happened
2:45AM
Inmate Sitting on bed
3:00AM
Inmate sitting on bed
3:15AM
Lt. Anderson takes pictures of inmate
3:30AM
Inmate Sitting on bed
3:45AM
Inmate sitting on bed
4:00AM
Inmate Sitting on bed
4:15AM
Inmate Sitting on bed
4:30AM
Inmate standing at door talking
4:45AM
Inmate standing at door talking
5:00AM
Inmate sitting on bed
5:15AM
Inmate standing at door
5:30AM
Inmate standing at door
5:45AM
Inmate standing at door
6:00AM
Inmate Standing at door
6:15AM
Inmate standing at door
6:30AM
Inmate standing at door
6:45AM
Inmate Standing at door
7:00 AM
Inmate standing at door
Note to all observers: Legibly print and sign your name at the beginning of your shift.
1
CONFIDENTIAL
SDNY_00009539
EFTA00033872


c1: EFTA00033702
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033702.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
To:
From:
Mail Delivery Subsystem <MAILER-DAEMON@DJJMDCJC01-PPOINT13.jcots.jutnet.net>
Sent:
Sun 8/11/2019 2:23:02 AM
Subject:
Return receipt
status.txt
headers.txt
The original message was received at Sun, 11 Aug 2019 02:21:18 GMT
from [10.187.9.62]
The following addresses had successful delivery notifications -----
(relayed to non-DSN-aware mailer)
Transcript of session follows -----
relayed; expect no further notifications
CONFIDENTIAL
SDNY_00009153
EFTA00033702


c1: EFTA00032951
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032951.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: White Collar Law360 <news@law360.com>
To:
Subject: Roger Stone's Fine, Supervision Term Also Lifted By Trump
Date: Tue, 14 Jul 2020 08:00:08 +0000
Law360 White
Collar
WHITE COLLAR
Tuesday, July 14, 2020
Follow Law360
TOP NEWS
Law360 Practice Groups of the
Roger Stone's Fine, Supervision Term Also Lifted By Trump
Year
The details of Republican political operative Roger Stone's commutation
came to light Monday, showing that President Donald Trump wiped out
Stone's supervised release and fine along with his prison sentence.
1 document attached Read full article
Berman Resists Talking Motives For Ouster In New Transcript
Former Manhattan U.S. Attorney Geoffrey Berman resisted attempts by
members of the House Judiciary Committee to get him to speculate on the
possible reasons for his controversial ouster last month, according to a
transcript of last week's closed-door congressional hearing made public on
Monday.
Transcript attached Read full article
LAW FIRMS
Have Too Many Cases? Judge Leon Doesn't Want To Hear It
Bleichmar Fonti
A government attorney wanted U.S. District Judge Richard J. Leon to
Boies Schiller
consider deadlines she faces in other cases before he issues a scheduling
Brannock & Humphries
order in a suit over a sex trafficking law, but the D.C. federal judge offered no
sympathy Monday, firing back that the administration has the staff to help her
Buckley LLP
meet the deadlines.
Crowell & Moring
Read full article
Davis Wright Tremaine
Dressman Benzinger
Weinstein Atty Defends Press Tactics That Sparked Gag Order
Duane Morris
Harvey Weinstein lawyer Donna Rotunno said Monday she had no choice but
Epstein Becker Green
to take her advocacy to the press during his sex assault trial, even though the
FeganScott
practice eventually prompted a judge to enter a gag order against her team
Fenwick & West
during jury deliberations.
Foley & Lardner
Read full article
Gibson Dunn
Weinstein Accusers Call $19M Class Deal 'A Cruel Hoax'
Goodwin
Several of Harvey Weinstein's accusers have lodged their opposition to the
Greenberg Traurig
proposed $18.9 million settlement the Hollywood producer and convicted
Hagens Berman
rapist reached to end a putative class action in New York alleging he sexually
Hill Ward Henderson
abused dozens of women, on Monday calling the deal "a cruel hoax" that
would benefit Weinstein more than his accusers.
Hogan Lovells
3 documents attached Read full article
Hutchinson Black
Jackson Lewis
DOJ Shuts Down Websites Shilling 'False' COVID-19 Vaccines
Keller Rohrback
A Kentucky federal judge on Monday ordered the shutdown of a series
Kirkland & Ellis
of related websites and a Facebook page offering preregistration for a
Kupferstein Manuel
EFTA00032951

=== Page 2 ===
nonexistent COVID-19 vaccine in exchange for $100 worth of bitcoin after the
Latham & Watkins
Louisville man prosecutors claim is behind the scam agreed to a preliminary
Lewis Brisbois
injunction.
Marie A. Mattox PA
2 documents attached Read full article
McDermott Will
SUPREME COURT REVIEW
Morris Nichols
Feature
O'Melveny & Myers
The Sharpest Dissents From The Supreme Court
Paul Hastings
Potter Anderson
Term
Pryor Cashman
The majority of this term's dissents came from the court's right-
Rheingold Giuffra
leaning justices, and many of their sharpest critiques stemmed from
Scott & Corley
suits over Trump administration policies. Here, Law360 looks at
Seward & Kissel
some of the fieriest.
Seyfarth Shaw
Read full article
Todd & Weld
Feature
Whistleblower Law Collaborative
The Chattiest Justice Of The Term Is
Wigdor LLP
WilmerHale
One justice again stood out as the chattiest member of the
Supreme Court this term. But that jurist's talk was tempered when
COMPANIES
the coronavirus pandemic forced the court to close its doors and
American Bar Association
conduct remote oral arguments, which were livestreamed for the
Associated Press
first time in history.
Booking.com BV
Read full article
Boston University
Cable-Satellite Public Affairs
Feature
Network
The Funniest Moments Of The Supreme Court's
Chevron Corp.
Term
Deloitte Touche
Electronic Frontier Foundation
Justice Stephen Breyer conjured up a baffling hypothetical involving
a Roman emperor, Chief Justice John Roberts stepped up his
Ernst & Young LLP
game on popular slang, and a toilet flushed loudly as a Latham &
Facebook Inc.
Watkins lawyer discussed constitutional rights. Here, Law360
Fossil Group Inc.
highlights the most mirthful moments from this past term's U.S.
HCP Inc.
Supreme Court arguments.
Institute for Justice
Read full article
Integreon Managed Solutions Inc.
KPMG International
PUBLIC INTEGRITY
Law Enforcement Employees
Benevolent Association
NY Police Union Boss Charged With Defrauding Annuity Fund
Lehman Brothers Holdings Inc.
Manhattan federal prosecutors on Monday accused the head of a New York
City law enforcement union of defrauding members by raiding the union's
LexisNexis Group
retirement fund.
Linkedln Corp.
Read full article
Morgan Stanley
NantKwest Inc.
LEGAL ETHICS
Netflix Inc.
Panama Papers Attys Fight Netflix Bid To Nix Defamation Suit
New York City Bar Association
Novartis AG
The attorneys whose now-defunct firm Mossack Fonseca was involved in the
Panama Papers scandal asked a California federal judge to reject Netflix's
Outokumpu
bid for dismissal of a suit alleging its movie "The Laundromat" was
PricewaterhouseCoopers
defamatory.
International Ltd.
2 documents attached
Read full article
Questcor Pharmaceuticals, Inc.
RELX PLC
HEALTH
Spartan Race Inc.
Thomson Reuters Corp.
EFTA00032952

=== Page 3 ===
6th Circ. Won't Overturn Pill Mill Operator's Conviction
Twitter Inc.
The Sixth Circuit on Friday upheld the conviction of a Michigan man for
University of Southern California
running an opioid pill mill, saying a jury instruction did not wrongly lead jurors
Washington Post Co.
to think that the standard required by "reasonable doubt" was lower than it
actually is.
GOVERNMENT AGENCIES
Opinion attached Read full article
Centers for Medicare & Medicaid
Services
Mallinckrodt Aims To Nix Medicaid FCA Suit Over Acthar Gel
Commodity Futures Trading
The government is wrongly conflating fraud with a regulatory disagreement,
Commission
Mallinckrodt ARD LLC told a Massachusetts federal court Monday, urging a
Federal Communications
judge to toss False Claims Act claims centering on its pricey H.P. Acthar Gel
Commission
drug, which treats infantile spasms and other conditions.
Federal Trade Commission
Memorandum attached
Read full article
Food and Drug Administration
Internal Revenue Service
SPORTS & BETTING
New York Attorney General's Office
California Couple Cops To 'Varsity Blues' Charges
U.S. Attorney's Office
A California couple will plead guilty to charges in the "Varsity Blues" college
U.S. Court of Appeals for the Sixth
admissions scandal, becoming the 27th and 28th parents to admit their guilt
Circuit
in the high-profile case in a pair of plea agreements filed late Friday.
U.S. Department of Homeland
2 documents attached Read full article
Security
U.S. Department of Justice
EXPERT ANALYSIS
U.S. District Court for the Central
District of California
5 Compliance Lessons From Novartis' FCPA Settlement
U.S. District Court for the District of
Novartis' parallel settlements with the U.S. Department of Justice and U.S.
Massachusetts
Securities and Exchange Commission to resolve criminal Foreign Corrupt
U.S. District Court for the Northern
Practices Act allegations emphasize risk points for life sciences companies,
District of California
especially for repeat offenders, say attorneys at Paul Hastings.
U.S. District Court for the Southern
Read full article
District of New York
Opinion
U.S. District Court for the Western
Criminal Contempt Charges In Donziger Case Are Excessive
District of Kentucky
We are deeply troubled by many aspects of a New York federal judge's
U.S. House of Representatives
criminal contempt case against human rights attorney Steven Donziger,
U.S. Patent and Trademark Office
including extraordinary and unfair pretrial home confinement, say retired U.S.
U.S. Securities and Exchange
District Judges Nancy Gertner and Mark Bennett.
Commission
Read full article
U.S. Senate
U.S. Supreme Court
Alleged ICO Fraud Highlights Compliance Considerations
Parallel U.S. Department of Justice and U.S. Securities and Exchange
Commission fraud charges connected with NAC Foundation's digital currency
offering draw attention to the use of undercover agents in financial crime
investigations, the risk of retaining questionable service providers, and
heightened securities law scrutiny in the space, says Casey O'Neill at
Fenwick.
2 documents attached
Read full article
Associates Can Prioritize Biz Development Despite Pandemic
Although many traditional business development activities are on hold due to
the COVID-19 pandemic, associates should seize the unique opportunities of
this time to cultivate business by strengthening their personal and
professional relationships, and developing new ones, says Jeremy Schneider
at Jackson Lewis.
Read full article
LEGAL INDUSTRY
EFTA00032953

=== Page 4 ===
Deloitte Expands Legal Business Services Unit To US
Deloitte is stepping up its alternative legal business service offerings in the
U.S. with the launch of a new practice that will offer legal management
consulting and technology services to companies, the Big Four accounting
firm announced Monday.
Read full article
Many In Atty Ranks Down About The Future Of Their Industry
Less than half of attorneys and legal industry professionals feel positive
about the future of the industry, according to a new survey by mentoring
organization MOSAIC Collective, with the biggest concerns being technology,
economic uncertainty and the industry's ability to adapt to change.
Read full article
Facebook Vies To Keep Gibson Dunn Probe Out Of Discovery
Facebook urged a California federal magistrate judge Monday to reject efforts
by users suing over the Cambridge Analytica scandal to review a Gibson
Dunn-led investigation, saying the law firm's look into possible misbehavior
by some Facebook developers is largely protected by attorney-client
privilege.
Read full article
Boies Schiller Adds Bankruptcy Attys In NY, London
Boies Schiller Flexner LLP has added the former head of derivatives
bankruptcy strategy at Lehman Brothers Holdings and the former executive
director of distressed special situations at Nomura International PLC to its
New York and London offices, respectively, the firm announced Monday.
Read full article
Foley & Lardner Can Foreclose On $29M Condo Loan
Foley & Lardner has standing to foreclose on a $29 million loan for a
condominium development, a Florida appeals court has ruled, after finding
that the law firm was the successor in interest to the loan servicer under an
asset management agreement.
Read full article
'Grim Reaper' Atty Blasts Fla. Gov.'s Virus 'Inaction' In Appeal
A Florida attorney who has made waves appearing as the Grim Reaper
across the state during the COVID-19 pandemic blasted Gov. Ron DeSantis
for his inaction as he urged a state appeals court to revive his case asking
the courts to impose beach closures and a statewide stay-at-home order.
Read full article
Legal Startup Says Westlaw Wants 'Monopoly' Over Law Texts
A legal research startup called ROSS Intelligence fired back Monday at a
copyright lawsuit filed by Westlaw owner Thomson Reuters, accusing the
bigger company of seeking "a monopoly over access to public legal texts."
Read full article
Interview
15 Minutes With Spartan Race's General Counsel
Spartan Race in mid-June held its first U.S. event since the outbreak of the
coronavirus, though the competition was "extremely modified" to ensure
safety, said general counsel Deanna Sheridan. Here, she explains some of
the biggest challenges her organization is facing and how she envisions
future obstacle race course events will look.
Read full article
EFTA00032954

=== Page 5 ===
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